Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-001: Segregation of Duties
Criteria: A strong internal control structure requires that duties be segregated so that one person does not have the ability to control all aspects of accounting functions. Adequate segregation of duties should exist among those who review and approve payments and those who prepare and submit the requests for payment.
Statement of Condition: The Foundation does not have adequate segregation of duties present for the approval of payments to subcontractors, which are reflected as federal subcontracts expense on the financial statements. The project manager, who was responsible for reviewing and approving the subcontractor’s invoices in preparation for payment authorization by members of the Foundation’s Board, was employed by the subcontractor.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. The project manager had the knowledge and availability to review the invoice submissions and related supporting documents on behalf of the Foundation.
Effect: A lack of segregation of duties increases the risk that errors or fraud relating to subcontractor invoices could occur and not be detected or that unallowable costs could be incurred.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation designate a person independent of the subcontractor to perform the initial review of the subcontractor’s requests for payment in advance of the payment authorization by the Foundation’s Board.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.
Finding 2022-002: Department of Health and Human Services – Research & Development Cluster – ALN #93.394, #93.395, and #93.399 – Subrecipient Monitoring
Criteria: 2 CFR section 200.332 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance, monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and is in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and verify that every subrecipient is audited as required by Subpart F, as necessary.
Statement of Condition: No formal documentation existed to indicate that the Foundation performed the required monitoring of its subrecipient’s activity and no written policy exists to establish procedures to document the monitoring of the subrecipient.
Cause: The Foundation does not have employees and is operated by a volunteer Board of Directors. Additionally, no formal policies were written to establish procedures to document monitoring of subrecipients.
Effect: A failure to monitor a subrecipient's compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Subrecipient monitoring was ineffective.
Questioned Costs: None.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that the Foundation establish written policies to document the monitoring of its subrecipient by an individual independent of the subrecipient. This policy should address all required elements of 2 CFR 200.332.
Views of Responsible Officials: Management agrees with finding; see separate corrective action plan.