Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Period of Performance
Finding Type: Material Weakness in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.403 (g) and (h), costs must be adequately documented and incurred during the approved budget period. Additionally, per 2 CFR Section 200.334, non-federal entity records pertinent to a federal award must be retained for a period of three years from the date of submission of the final expenditure report.
Condition and context: During our period of performance testing, management was unable to provide documentation to support one out of the eight statistically valid samples.
Cause: The Organization did not have controls in place to maintain documentation of project expenses.
Effect: Failure to obtain sufficient support for payments made could result in inappropriate costs charged to the federal award during the approved budget period.
Questioned Costs: $77,862 (known). $174,680 (likely).
Repeat finding: No.
Recommendation: We recommend that the Organization implement procedures to maintain adequate records.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Allowable Costs/Cost Principles - Payroll Allocations
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.430, charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed.
Condition and context: Payroll costs charged to the program were not based on actual hours worked. This condition was noted for two statistically valid samples.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.430.
Effect: Estimated payroll charges to the federal award were not adjusted to reflect actual time spent.
Questioned Costs: $15,701 (known), $94,514 (likely).
Repeat finding: No.
Recommendation: We recommend the Organization implement procedures to review and approve time spent on each award.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.
Reporting
Finding Type: Material Weakness Internal control over compliance and noncompliance Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: According to 2 CFR Section 200.329 (c)(1), the non-federal entity must submit performance reports at the interval required by the pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually, and a subrecipient must submit to a pass-through entity, no later than 90 calendar days after the period of performance end date, all final performance
reports as required by the terms and conditions of the Federal award.
Condition and context: The Organization could not provide the final reports for two different grants, nor did they maintain adequate documentation that reports were reviewed and filed. This condition was noted during the testing of four statistically valid samples.
Cause: The Organization had ineffective controls in place for reporting and related recordkeeping in accordance with 2 CFR Section 200.329 (c)(1).
Effect: Without adequate controls in place to ensure projects submit accurate reports on a timely basis, reporting requirements may not be met or reporting could be inaccurate.
Questioned Costs: None.
Repeat finding: No.
Recommendation: We recommend that the Organization implement policies and procedures to ensure federally required reports prepared by their projects are reviewed.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.