Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-002 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) Pass-Through Grantor: Not applicable Pass-Through Award Number: Not applicable Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? The Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions states the following: ?In order to accept a payment, must the provider have already incurred eligible expenses and losses higher than the Provider Relief Fund payment received? (Modified 6/11/2021). No. Providers do not need to be able to prove that prior and/or future lost revenues and expenses attributable to COVID-19 (excluding those covered by other sources of reimbursement) meet or exceed their Provider Relief Fund payment at the time they accept such a payment. Providers must report on the use of Provider Relief Fund payments in accordance with legal and program requirements in the relevant Reporting Time Period. Recipients may use payments for eligible expenses incurred prior to receipt of those payments (i.e., pre-award costs) so long as they are to prevent, prepare for, and respond to coronavirus. Providers must follow their basis of accounting to determine expenses. Duplication of expenses and lost revenues is not permitted. All recipients are subject to audit.? ?If a Reporting Entity has more lost revenues for a ?Payment Received Period? than it received Provider Relief Fund and/or ARP Rural payments for the same period, can those lost revenues be carried forward and applied against payments received during later ?Payment Received Periods? and included in the lost revenues reported during later reporting periods? (Modified 5/5/2023) Yes. Provider Relief Fund and/or ARP Rural payments may be applied to expenses and lost revenues according to the period of availability of funding. However, expenses and lost revenues may not be duplicated. Specifically, payments received may not be applied to the same expenses and lost revenues that Provider Relief Fund or ARP Rural payments received in prior payment periods already reimbursed. The Payment Received Periods described in the Post-Payment Notice of Reporting Requirements determine the period of availability of funding and when reports are due. The opportunity to apply Provider Relief Fund payments (excluding the Nursing Home Infection Control Distribution) and ARP Rural payments for lost revenues will be available up to June 30, 2023, the end of the quarter in which the COVID-19 Public Health Emergency ends.? Condition: Management did not have sufficiently designed internal controls over the review and interpretation of HRSA PRF portal instructions for the input of the lost revenue amounts into the HRSA PRF portal for Spectrum Health System (the Parent), TIN 383382353, General Distribution HRSA PRF report and the individual subsidiary Targeted Distribution HRSA PRF reports. Cause: Management?s internal controls over the review and interpretation of instructions related to the input of lost revenue into the HRSA PRF portal were not sufficient to ensure the lost revenue recorded in the General Distribution portal ?Total Lost Revenues for the Period of Availability (January 1, 2020 to December 31, 2022)? line did not include the lost revenues that had been transferred from the Parent to subsidiaries and recorded in the portal for the subsidiaries Targeted Distributions. Effect or Potential Effect: The lost revenues reported in the HRSA PRF portal were misstated. Questioned Costs: None Context: There were a total of eighteen HRSA PRF reports submitted for the year ended December 31, 2022. We tested a sample of five HRSA PRF reports. Per our inspection of our sample of five Corewell Health West HRSA PRF portal submissions for reporting period 4, the General Distribution and four Targeted Distributions, we identified two Targeted Distributions where the lost revenue allocated to the subsidiaries in the Targeted Distributions were also included in the Parent lost revenue portal for the ?Total Lost Revenue for the Period of Availability (January 1, 2020 to December 31, 2022)? line for the General Distribution. Per our inspection of the lost revenue calculation, we noted that five entities utilized lost revenue transferred from the Parent in reporting period 4. In aggregate, this resulted in an overstatement of lost revenues of $23,104,664 in the Parent General Distribution HRSA PRF portal. Total Lost Revenues for the Period of Availability (January 1, 2020 to December 31, 2022) reported in the Reporting Period 4 General Distribution was $228,959,327. The correct amount of lost revenue reported for Period 4 should have been $205,854,663. Total expenses reported on the Schedule for PRF for the year ended December 31, 2022 are $42,175,576. Identification as a Repeat Finding: Partial repeat of 2021-008. Recommendation: We recommend that management implement more robust internal controls for review of the instructions for the HRSA PRF Portal. Views of Responsible Officials: When populating the Period 4 HRSA PRF portal for Spectrum Health System, Corewell Health West management was aware that the inputs were not appropriately considering the System lost revenue attributed to the affiliates. In order to communicate to the users of the portal and other auditors, Management included an excel tracking worksheet which was upload on the HRSA PRF portal showing the total lost revenue used as an organization and the remaining balance left to be used. When populating the Period 5 filing, due September 30, 2023, Corewell Health West Management will correctly input the lost revenue in the Parent submission in order to reflect the lost revenue used by the individual subsidiaries.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-002 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (PRF) Pass-Through Grantor: Not applicable Pass-Through Award Number: Not applicable Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? The Provider Relief Programs: Provider Relief Fund and ARP Rural Payments Frequently Asked Questions states the following: ?In order to accept a payment, must the provider have already incurred eligible expenses and losses higher than the Provider Relief Fund payment received? (Modified 6/11/2021). No. Providers do not need to be able to prove that prior and/or future lost revenues and expenses attributable to COVID-19 (excluding those covered by other sources of reimbursement) meet or exceed their Provider Relief Fund payment at the time they accept such a payment. Providers must report on the use of Provider Relief Fund payments in accordance with legal and program requirements in the relevant Reporting Time Period. Recipients may use payments for eligible expenses incurred prior to receipt of those payments (i.e., pre-award costs) so long as they are to prevent, prepare for, and respond to coronavirus. Providers must follow their basis of accounting to determine expenses. Duplication of expenses and lost revenues is not permitted. All recipients are subject to audit.? ?If a Reporting Entity has more lost revenues for a ?Payment Received Period? than it received Provider Relief Fund and/or ARP Rural payments for the same period, can those lost revenues be carried forward and applied against payments received during later ?Payment Received Periods? and included in the lost revenues reported during later reporting periods? (Modified 5/5/2023) Yes. Provider Relief Fund and/or ARP Rural payments may be applied to expenses and lost revenues according to the period of availability of funding. However, expenses and lost revenues may not be duplicated. Specifically, payments received may not be applied to the same expenses and lost revenues that Provider Relief Fund or ARP Rural payments received in prior payment periods already reimbursed. The Payment Received Periods described in the Post-Payment Notice of Reporting Requirements determine the period of availability of funding and when reports are due. The opportunity to apply Provider Relief Fund payments (excluding the Nursing Home Infection Control Distribution) and ARP Rural payments for lost revenues will be available up to June 30, 2023, the end of the quarter in which the COVID-19 Public Health Emergency ends.? Condition: Management did not have sufficiently designed internal controls over the review and interpretation of HRSA PRF portal instructions for the input of the lost revenue amounts into the HRSA PRF portal for Spectrum Health System (the Parent), TIN 383382353, General Distribution HRSA PRF report and the individual subsidiary Targeted Distribution HRSA PRF reports. Cause: Management?s internal controls over the review and interpretation of instructions related to the input of lost revenue into the HRSA PRF portal were not sufficient to ensure the lost revenue recorded in the General Distribution portal ?Total Lost Revenues for the Period of Availability (January 1, 2020 to December 31, 2022)? line did not include the lost revenues that had been transferred from the Parent to subsidiaries and recorded in the portal for the subsidiaries Targeted Distributions. Effect or Potential Effect: The lost revenues reported in the HRSA PRF portal were misstated. Questioned Costs: None Context: There were a total of eighteen HRSA PRF reports submitted for the year ended December 31, 2022. We tested a sample of five HRSA PRF reports. Per our inspection of our sample of five Corewell Health West HRSA PRF portal submissions for reporting period 4, the General Distribution and four Targeted Distributions, we identified two Targeted Distributions where the lost revenue allocated to the subsidiaries in the Targeted Distributions were also included in the Parent lost revenue portal for the ?Total Lost Revenue for the Period of Availability (January 1, 2020 to December 31, 2022)? line for the General Distribution. Per our inspection of the lost revenue calculation, we noted that five entities utilized lost revenue transferred from the Parent in reporting period 4. In aggregate, this resulted in an overstatement of lost revenues of $23,104,664 in the Parent General Distribution HRSA PRF portal. Total Lost Revenues for the Period of Availability (January 1, 2020 to December 31, 2022) reported in the Reporting Period 4 General Distribution was $228,959,327. The correct amount of lost revenue reported for Period 4 should have been $205,854,663. Total expenses reported on the Schedule for PRF for the year ended December 31, 2022 are $42,175,576. Identification as a Repeat Finding: Partial repeat of 2021-008. Recommendation: We recommend that management implement more robust internal controls for review of the instructions for the HRSA PRF Portal. Views of Responsible Officials: When populating the Period 4 HRSA PRF portal for Spectrum Health System, Corewell Health West management was aware that the inputs were not appropriately considering the System lost revenue attributed to the affiliates. In order to communicate to the users of the portal and other auditors, Management included an excel tracking worksheet which was upload on the HRSA PRF portal showing the total lost revenue used as an organization and the remaining balance left to be used. When populating the Period 5 filing, due September 30, 2023, Corewell Health West Management will correctly input the lost revenue in the Parent submission in order to reflect the lost revenue used by the individual subsidiaries.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-004 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not have an internal control over the review and approval of the fringe rate application control for Corewell Health West from January 1 to October 31, 2022. Cause: Management did not implement an internal control over the fringe rate application for Corewell Health West from January 1 to October 31, 2022. Effect or Potential Effect: The fringe rate applied to a grant may be inaccurate. Questioned Costs: None. Context: Per inquiry of management, the internal control over the review and approval of the fringe rate applied by Workday was not put into place until November 2022. Corewell Health West fringe costs totaled $724,020, which represents 6.9% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management continue to perform the internal control over the fringe rate implemented in November 2022. Views of Responsible Officials: Management will continue to perform the internal control over the fringe rate implemented in November 2022.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-005 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR section 200.403(h)) states: ?Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3).? Condition: Management does not track expenses by budget period for Corewell Health East federal Research and Development (R&D) grants and is therefore unable to support that expenses are recorded in the appropriate period of performance. Cause: Management?s General Ledger system was not designed to record R&D expenditures by budget period. Effect or Potential Effect: Expenses could be expensed outside the period performance. Questioned Costs: Unknown Context: Corewell Health East has twenty-five R&D grants. We were unable to test period of performance for seven grants, totalling $765,791, which had budget periods beginning or ending during the audit period. As such, we were unable to conclude if expenses were incurred in the appropriate budget period. Total R&D Cluster expenditures reported on the Schedule for Corewell Health East are $3,348,876 for the year ended December 31, 2022, The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management design appropriate cost structure to monitor R&D expenditures by performance period Views of Responsible Officials: The hierarchy and functionality of the Corporate financial management system does not support separate budget periods during a single award project period. This was managed manually by the CHE Sponsored Programs Administration via a customized internal report. Effective 7/1/2023, the System transitioned Corewell Health East onto Workday, the common financial management system used by Corewell Health West. The Workday financial management system includes a separate grant module that has the capability to establish defined budget periods under a single award. With the functionality now enabled by Workday, we do not anticipate any barriers to maintaining defined budget periods within an award funding cycle to assure that expenses are recorded in the appropriate period of performance.
Finding 2022-001 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: Various Federal Agency: Department of Homeland Security Assistance Listing: 97.036 ? COVID-19 Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Grantor: Michigan State Police Emergency Management and Homeland Security Division Pass-Through Award Number: 4494-DR-MI Pass-Through Award Period: 1/20/2020-7/1/2022 Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Assistance Listing: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Pass-Through Award Period: 1/1/2020-12/31/2022 (Periods 3 and 4) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? 2 CFR 200.510 requires that the ?auditee must also prepare a Schedule of Expenditures of Federal Awards for the period covered by the auditee?s financial statements which must include the total Federal awards expended in accordance with Section 200.502.? These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States and the ?Internal Control Integrated Framework? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Schedule of Expenditures of Federal Awards (the Schedule) prepared by the Corewell Health and Subsidiaries (the System) did not appropriately reflect the federal expenses incurred. The final Schedule was corrected for the differences identified. Cause: Management did not design internal controls to ensure appropriate accumulation of the data necessary to complete the Schedule. Effect or Potential Effect: Federal expenditures were inappropriately included or excluded from the Schedule. Questioned Costs: None Context: Total federal expenses included on the Schedule were $102,235,937 for the year ended December 31, 2022. Total expenses included on the final Schedule were $101,562,371 for the year ended December 31, 2022. The federal expenditures were misstated as follows: See Schedule of Findings and Questioned Costs. Identification as a Repeat Finding: Partial Repeat Finding of Corewell Health East 2021-001. Recommendation: Management should assess its internal controls over the identification of federal expenditures to ensure the Schedule is complete. Views of Responsible Officials: The enhanced Schedule process and controls implemented by Corewell Health East in 2023 will be reviewed. The misstated amounts of the R&D Cluster occurred as a result of the timing of posted expenses during the first month of the merger of Spectrum Health and Beaumont Health in February 2022. This was a one-time occurrence and we do not anticipate that this will be an issue in future years. In addition, the successful implementation and transition to Workday, a new Corporate financial management system, has improved award setup functionality that enables improved differentiation of awards, identifying which need to be included on the annual Schedule of Expenditures of Federal Awards and those that should be excluded. The understatement related to FEMA was a one-time occurrence related to the clarification of guidelines on the inclusion of a new Category Z FEMA obligation in 2022 on the SEFA. This has been corrected in 2023. The overstatement related to PRF was due to an improper inclusion of Corewell Health East funding on the Schedule and an adjustment related to the submitted amount of Corewell Health West funding on the Schedule. On the 2023 SEFA we will implement a management review and sign-off of the inputs prior to submission.
Finding 2022-003 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various, Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management does not have policies and procedures that require documented review and approval of 100% of each employee?s effort certification related to Corewell Health West. Management does document the review and approval of employee effort associated with grants. Management does not have a control over the review and approval of effort certifications for physicians related to Corewell Health East. Cause: Management?s policy over effort reporting for Corewell Health West was designed to only require the documented review and approval of the grant effort and not 100% of an employee?s effort, which includes effort spent on administrative responsibilities. Management?s policy related to Corewell Health East effort for physicians who are not the principal investigator who charge time to the R&D grants does not require their effort report be reviewed and approved by someone who is knowledgeable of the grant. Effect or Potential Effect: Effort charged to a federal grant may be inaccurate. Questioned Costs: None. Context: For Corewell Health West, we tested 40 payroll transactions ($172,432). Per inspection of the effort certifications for each employee, the effort associated to R&D was reviewed and approved. The review and approval of the employees? administrative effort was not documented. Corewell Health West payroll costs were $3,621,173, which represents 34.5% of total R&D Cluster expenditures. For Corewell Health East, we tested 41 salary payroll transactions ($99,594). Per inspection of our selection support, 16 instances ($28,426) were related to physicians that did not have their R&D effort certification reviewed and approved for that certification period. Corewell Health East physician payroll costs were $433,781, which represents 4.1% of total R&D Cluster expenditures. The total R&D Cluster expenditures reported on the Schedule are $10,507,754 for the year ended December 31, 2022. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management should update its policies to require the reviewers to review 100% of each employee?s effort. Views of Responsible Officials: Corewell Health West utilizes Workday Grants Management to document the employee self-certification for 100% of each employee?s effort. In addition to the employee self-certification, Management will enable Workday functionality to route the effort certification for approval to a reviewer with knowledge of 100% of the employee?s effort. Corewell Health East will update their Research Time and Effort Reporting policy to reflect that review of the monthly RI Time and Effort Report for Physicians submitted by physicians who are involved as key personnel on federal grants or applicable direct expense reimbursement mechanisms, whether or not compensation is received, will be reviewed by an individual who is familiar with the technical/scientific progress of the award.
Finding 2022-006 Identification of the Federal Program: Federal Agency: U.S. Department of Health and Human Services, United States Department of Defense Assistance Listing: Various ? Research & Development (R&D) Cluster Pass-Through Grantor: Various Pass-Through Award Number: Various Pass-Through Award Period: 1/1/2022-12/31/2022 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR Section 200.303 of the Uniform Guidance States the Following Regarding Internal Control: ?The Non-Federal Entity Must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Condition: Management did not retain evidence to support their review over the patient data submitted to Sponsor for the per diem billings from February 1, 2022 to December 31, 2022 was complete and accurate. Cause: Management?s internal controls and policies over the review and approval of study activities did not reference supporting patient data documentation reviewed. Effect or Potential Effect: Unallowable patient?s may be reimbursed by the Sponsor. Questioned Costs: None. Context: The System had $364,606 of per diem contracts in 2022 related to research and development grants that are included on the Schedule. Total federal expenditures related to the research and development cluster were $10,507,754 in 2022. Identification as a Repeat Finding: 2021-003 Recommendation: Research Administration should review its internal controls and policies to require a documented review of the detailed study visit reports and retain the underlying evidence to support the review procedures. Views of Responsible Officials: The current attestation memo control will be replaced as follows. There are two categories of study activity that required review and approval by the appropriate individual (i.e., Principal Investigator, Clinical Research Manager (CRM) or a delegate): (1) at the time of enrollment to assure that the study participant met sponsor-defined eligibility requirements and (2) subsequent study activities that may include but are not limited to a study visit, data collection, follow-up phone call, questionnaire completion, laboratory testing, biospecimen collection, or some combination of these. Verification of eligibility at the time of enrollment will continue to be reviewed and approved by the study PI, CRM, or appropriate delegate per sponsor requirements. Documentation is maintained in study-specific binders, per FDA audit standards and internationally-accepted Good Clinical Practice principles to assure that only patients meeting the sponsor?s defined eligibility criteria are enrolled into the study. Review of study activities subsequent to the study participant enrollment will be conducted monthly by the CRM or their delegate. Sponsored Programs Administration (SPA) will prepare and send each CRM a Transaction Report downloaded from the institutional clinical trial management system for each federally funded study, at least quarterly, that includes a listing of study visits associated with enrolled study participants that occurred within the defined period of time. The CRM/delegate will review the report detail provided and, upon approval, sign and date the report. To assure that the information in the report is consistent with what was submitted to third parties which generates reimbursement, the CRM/delegate will conduct an audit of a sample of patients from a random selection of studies included in the Transaction Report. Each sample will be verified against documentation maintained in the study binder. Audit results affirming document review will be recorded in an audit tracking log which will be retained with the study activity report in their Clinical Trial Office (CTO) file as evidence of their review of study activity for federally funded fixed fee/per patient studies. For those federally-funded fixed fee/per patient studies that do not utilize the standard institutional clinical trial management system, a similar study activity report downloaded from the clinical trial management system utilized for the study will be used for review, signed and dated upon approval and kept in the CTO files as evidence of review.