Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-004 – Subrecipient Monitoring
Information of the federal program:
Federal Grantor: United States Department of Health and Human Services
Pass-Through Grantor: City of Chicago
Assistance Listing No.: 93.391, Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Section 200.332 of the Uniform Guidance states that all pass-through entities must:
“(b) 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 described in paragraphs (d) and (e) of this section, which may include consideration of such factors as:
(1) The subrecipient’s prior experience with the same or similar subawards,
(2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program,
(3) Whether the subrecipient has new personnel or new or substantially changed systems, and
(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).”
Section 200.332 of the Uniform Guidance further states that all pass-through entities must:
“(g) Consider whether the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records.”
Condition:
Although subrecipient monitoring procedures were performed during the fiscal year, management did not perform and document a risk assessment upon entering into subaward agreements with its subrecipients in order to determine the extent of monitoring procedures that should be performed to be responsive to the assessed risk. In addition, management did not obtain the Uniform Guidance audit report from its subrecipients.
Cause:
Management did not have internal controls in place that required completion of the documentation evidencing review of the risk assessment of the subrecipients at the beginning of the award and monitoring of the Uniform Guidance audit reports of the subrecipients. The documentation was not completed as management considered the subrecipients vendors.
Questioned costs:
None.
Context:
Total federal expenditures passed through to subrecipients that required a risk assessment of and review of the Uniform Guidance audit report reported in the Schedule were $885,840, representing 70.20% of total STLT expenditures of $1,261,948 for the year ended December 31, 2023.
Effect or potential effect:
Monitoring performed over a subrecipient may not be responsive to the risk for that subrecipient. A subrecipient’s Uniform Guidance audit report could contain findings that are not properly reviewed and evaluated.
Identification as a repeat finding, if applicable:
The finding is not a repeat finding.
Recommendation:
Management should establish written internal controls and procedures related to subrecipient risk assessments in accordance with Uniform Guidance Section 200.33 2(b). In addition, Endeavor should modify the subrecipient Uniform Guidance audit report review process to include a section for Endeavor to document its review of and conclusions reached over the subrecipient’s Uniform Guidance audit report.
Views of Responsible Officials:
Management will establish written internal procedures related to sub-recipient risk assessments in accordance with the Uniform Guidance Section 200.33 2(b). Management will leverage its key resources at the system level to improve the process for R&D sub-recipients assessment and monitoring. In addition, management will consult with legal, finance, and compliance teams to evaluate and correct, if necessary, current review processes and documentation of review results moving forward.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Information of the federal program:
Federal Grantor: United States Department of Health and Human Services
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Wisconsin – Madison
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Section 200.430 states the following: (d) Unallowable costs.
The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
(1) Costs which are unallowable under other sections of these principles must not be allowable under this section solely on the basis that they constitute personnel compensation.
(2) For the amount of the ceiling for cost-reimbursement contracts, the covered compensation subject to the ceiling, the covered employees, and other relevant provisions, see 10 U.S.C. 2324(e)(1)(P), and 41 U.S.C. 1127 and 4304(a)(16). For other types of Federal awards, other statutory ceilings may apply.The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
Condition:
The salary expense recorded for employees above the NIH salary cap was not calculated correctly as it did not properly take into consideration the NIH salary cap requirements.
Cause:
Management did not calculate the NIH salary cap requirement correctly; therefore, the allowable payroll expense reported was overstated.
Effect or potential effect:
Payroll expenditures exceeding the NIH salary cap were charged to the research and development grants.
Questioned costs:
$819, which represents the payroll costs incurred for the pay period selected in excess of the salary cap amounts related to the following federal awards:
93.866 $434
93.837 $385
Context:
We selected 40 payroll transactions which totaled $32,051 from a payroll population of $5,471,507 for the year ended December 31, 2023. We identified 4 instances, which represented total salary cost of $2,337, where the salary cap amounts were not calculated correctly and, therefore, the salary expense charged to the grants was overstated by $819.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to review the salary cap adjustment calculation to ensure that the salary expenses charged to the program are appropriate.
Views of responsible officials:
The Research Institute has had a long-standing practice of reviewing salary cap limitations on grants. During the initial meeting for a new award (“The Kick-Off meeting”), the level of effort for proposed staff is confirmed, and any staff salaries exceeding the current salary cap were identified. This ensured that appointments on grants were appropriately updated. Due to changes in the GM10 not under the purview of the Research Institute select effort distributions were inadvertently changed to accommodate salary changes.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Information of the federal program:
Federal Grantor: United States Department of Health and Human Services
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Wisconsin – Madison
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Section 200.430 states the following: (d) Unallowable costs.
The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
(1) Costs which are unallowable under other sections of these principles must not be allowable under this section solely on the basis that they constitute personnel compensation.
(2) For the amount of the ceiling for cost-reimbursement contracts, the covered compensation subject to the ceiling, the covered employees, and other relevant provisions, see 10 U.S.C. 2324(e)(1)(P), and 41 U.S.C. 1127 and 4304(a)(16). For other types of Federal awards, other statutory ceilings may apply.The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
Condition:
The salary expense recorded for employees above the NIH salary cap was not calculated correctly as it did not properly take into consideration the NIH salary cap requirements.
Cause:
Management did not calculate the NIH salary cap requirement correctly; therefore, the allowable payroll expense reported was overstated.
Effect or potential effect:
Payroll expenditures exceeding the NIH salary cap were charged to the research and development grants.
Questioned costs:
$819, which represents the payroll costs incurred for the pay period selected in excess of the salary cap amounts related to the following federal awards:
93.866 $434
93.837 $385
Context:
We selected 40 payroll transactions which totaled $32,051 from a payroll population of $5,471,507 for the year ended December 31, 2023. We identified 4 instances, which represented total salary cost of $2,337, where the salary cap amounts were not calculated correctly and, therefore, the salary expense charged to the grants was overstated by $819.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to review the salary cap adjustment calculation to ensure that the salary expenses charged to the program are appropriate.
Views of responsible officials:
The Research Institute has had a long-standing practice of reviewing salary cap limitations on grants. During the initial meeting for a new award (“The Kick-Off meeting”), the level of effort for proposed staff is confirmed, and any staff salaries exceeding the current salary cap were identified. This ensured that appointments on grants were appropriately updated. Due to changes in the GM10 not under the purview of the Research Institute select effort distributions were inadvertently changed to accommodate salary changes.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-004 – Subrecipient Monitoring
Information of the federal program:
Federal Grantor: United States Department of Health and Human Services
Pass-Through Grantor: City of Chicago
Assistance Listing No.: 93.391, Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Section 200.332 of the Uniform Guidance states that all pass-through entities must:
“(b) 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 described in paragraphs (d) and (e) of this section, which may include consideration of such factors as:
(1) The subrecipient’s prior experience with the same or similar subawards,
(2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program,
(3) Whether the subrecipient has new personnel or new or substantially changed systems, and
(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).”
Section 200.332 of the Uniform Guidance further states that all pass-through entities must:
“(g) Consider whether the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records.”
Condition:
Although subrecipient monitoring procedures were performed during the fiscal year, management did not perform and document a risk assessment upon entering into subaward agreements with its subrecipients in order to determine the extent of monitoring procedures that should be performed to be responsive to the assessed risk. In addition, management did not obtain the Uniform Guidance audit report from its subrecipients.
Cause:
Management did not have internal controls in place that required completion of the documentation evidencing review of the risk assessment of the subrecipients at the beginning of the award and monitoring of the Uniform Guidance audit reports of the subrecipients. The documentation was not completed as management considered the subrecipients vendors.
Questioned costs:
None.
Context:
Total federal expenditures passed through to subrecipients that required a risk assessment of and review of the Uniform Guidance audit report reported in the Schedule were $885,840, representing 70.20% of total STLT expenditures of $1,261,948 for the year ended December 31, 2023.
Effect or potential effect:
Monitoring performed over a subrecipient may not be responsive to the risk for that subrecipient. A subrecipient’s Uniform Guidance audit report could contain findings that are not properly reviewed and evaluated.
Identification as a repeat finding, if applicable:
The finding is not a repeat finding.
Recommendation:
Management should establish written internal controls and procedures related to subrecipient risk assessments in accordance with Uniform Guidance Section 200.33 2(b). In addition, Endeavor should modify the subrecipient Uniform Guidance audit report review process to include a section for Endeavor to document its review of and conclusions reached over the subrecipient’s Uniform Guidance audit report.
Views of Responsible Officials:
Management will establish written internal procedures related to sub-recipient risk assessments in accordance with the Uniform Guidance Section 200.33 2(b). Management will leverage its key resources at the system level to improve the process for R&D sub-recipients assessment and monitoring. In addition, management will consult with legal, finance, and compliance teams to evaluate and correct, if necessary, current review processes and documentation of review results moving forward.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Information of the federal program:
Federal Grantor: United States Department of Health and Human Services
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Wisconsin – Madison
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Section 200.430 states the following: (d) Unallowable costs.
The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
(1) Costs which are unallowable under other sections of these principles must not be allowable under this section solely on the basis that they constitute personnel compensation.
(2) For the amount of the ceiling for cost-reimbursement contracts, the covered compensation subject to the ceiling, the covered employees, and other relevant provisions, see 10 U.S.C. 2324(e)(1)(P), and 41 U.S.C. 1127 and 4304(a)(16). For other types of Federal awards, other statutory ceilings may apply.The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
Condition:
The salary expense recorded for employees above the NIH salary cap was not calculated correctly as it did not properly take into consideration the NIH salary cap requirements.
Cause:
Management did not calculate the NIH salary cap requirement correctly; therefore, the allowable payroll expense reported was overstated.
Effect or potential effect:
Payroll expenditures exceeding the NIH salary cap were charged to the research and development grants.
Questioned costs:
$819, which represents the payroll costs incurred for the pay period selected in excess of the salary cap amounts related to the following federal awards:
93.866 $434
93.837 $385
Context:
We selected 40 payroll transactions which totaled $32,051 from a payroll population of $5,471,507 for the year ended December 31, 2023. We identified 4 instances, which represented total salary cost of $2,337, where the salary cap amounts were not calculated correctly and, therefore, the salary expense charged to the grants was overstated by $819.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to review the salary cap adjustment calculation to ensure that the salary expenses charged to the program are appropriate.
Views of responsible officials:
The Research Institute has had a long-standing practice of reviewing salary cap limitations on grants. During the initial meeting for a new award (“The Kick-Off meeting”), the level of effort for proposed staff is confirmed, and any staff salaries exceeding the current salary cap were identified. This ensured that appointments on grants were appropriately updated. Due to changes in the GM10 not under the purview of the Research Institute select effort distributions were inadvertently changed to accommodate salary changes.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-003 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Information of the federal program:
Federal Grantor: United States Department of Health and Human Services
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Wisconsin – Madison
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Section 200.430 states the following: (d) Unallowable costs.
The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
(1) Costs which are unallowable under other sections of these principles must not be allowable under this section solely on the basis that they constitute personnel compensation.
(2) For the amount of the ceiling for cost-reimbursement contracts, the covered compensation subject to the ceiling, the covered employees, and other relevant provisions, see 10 U.S.C. 2324(e)(1)(P), and 41 U.S.C. 1127 and 4304(a)(16). For other types of Federal awards, other statutory ceilings may apply.The NIH allowable compensation for certain employees is subject to a ceiling in accordance with statute.
Condition:
The salary expense recorded for employees above the NIH salary cap was not calculated correctly as it did not properly take into consideration the NIH salary cap requirements.
Cause:
Management did not calculate the NIH salary cap requirement correctly; therefore, the allowable payroll expense reported was overstated.
Effect or potential effect:
Payroll expenditures exceeding the NIH salary cap were charged to the research and development grants.
Questioned costs:
$819, which represents the payroll costs incurred for the pay period selected in excess of the salary cap amounts related to the following federal awards:
93.866 $434
93.837 $385
Context:
We selected 40 payroll transactions which totaled $32,051 from a payroll population of $5,471,507 for the year ended December 31, 2023. We identified 4 instances, which represented total salary cost of $2,337, where the salary cap amounts were not calculated correctly and, therefore, the salary expense charged to the grants was overstated by $819.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to review the salary cap adjustment calculation to ensure that the salary expenses charged to the program are appropriate.
Views of responsible officials:
The Research Institute has had a long-standing practice of reviewing salary cap limitations on grants. During the initial meeting for a new award (“The Kick-Off meeting”), the level of effort for proposed staff is confirmed, and any staff salaries exceeding the current salary cap were identified. This ensured that appointments on grants were appropriately updated. Due to changes in the GM10 not under the purview of the Research Institute select effort distributions were inadvertently changed to accommodate salary changes.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.
Finding 2023-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: University of Rochester, University of Wisconsin – Madison.
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantor: University of Washington
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management did not have sufficiently designed internal controls to retain documentation of the review of effort reports and, therefore, could not evidence the review of the effort reporting.
Cause:
Management did not retain evidence of approval of effort certifications for certain employees from January 1, 2023 to September 30, 2023.
In addition, the review of effort reports was not timely performed from October 1, 2023 to December 31, 2023.
Effect or potential effect:
Unallowable payroll costs may be charged to the federal program.
Questioned costs:
None.
Context:
We tested a sample of 18 payroll expenses, which totaled $11,080, for the period January 1, 2023 to September 30, 2023 and identified 5 transactions tested, which totaled $826, for which management did not retain support to document the effort report was reviewed for the period.
We tested a sample of 22 payroll expenses, which totaled $7,047, for the period October 1, 2023 to December 31, 2023 and noted that management did not perform a timely review of the effort certifications.
The total R&D Cluster expenditures reported on the Schedule are $13,409,825 for the year ended December 31, 2023. Payroll costs totaled $5,471,507, representing 40.79% of the total R&D Cluster expenditures.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should ensure effort report certifications and approvals are retained and timely performed.
Views of responsible officials:
The effort reporting practice at the Research Institute used automated messages to send certifications to the appropriate supervisor responsible for certifying the effort of the individuals charged to grants. The emails were maintained in a file that was checked to confirm the receipt of certifications. Management maintained records for the months January through August but the month of September is indeed missing. The process was disrupted in the last quarter of 2023 with the implementation of the new accounting system, Workday. The new Workday time and effort certification was not functional until the early months of 2024 and was the cause of the untimely certifications.
The new system is now operational. A new policy is being drafted along with new procedures. This system now requires that each individual certify their own time and effort and training will be provided to all staff this year.
Finding 2023-005 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantors: Rutgers State University, University of Chicago, Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantors: University of Chicago, Duke University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Criteria or specific requirement (including statutory, regulatory or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Condition:
Management develops a fringe benefit rate annually that is used to allocate fringe benefits to the research and development programs from January 1, 2023 to December 31, 2023. Management did not have internal controls to review the appropriateness of the journal entries recorded for fringe benefit rates.
Cause:
Management does not have internal controls and policies and procedures to require an appropriate review of fringe benefit journal entries.
Effect or potential effect:
Unallowable expenses may be inappropriately applied to research and development grants.
Questioned costs:
None.
Context:
We tested a sample of 16 fringe benefit journal entries to review. Based on the procedures performed, we identified that the fringe benefit costs were not reviewed timely by the appropriate individual.
The Company incurred $673,983 of fringe benefits in 2023 related to Research and Development grants that are included on the Schedule of Expenditures of Federal Awards. Total federal expenditures related to the research and development cluster were $13,409,825 for the year ended December 31, 2023.
Identification as a repeat finding, if applicable:
This finding is not a repeat finding from the prior year.
Recommendation:
Management should revise its internal controls and policies to require the appropriate review and approval of fringe benefit journal entries.
Views of responsible officials:
Management will document a policy to review the updated fringe rate on an annual basis and ensure the fringe expense charged to the grants is in line with the policy and the calculated rate.
Finding 2023-001 – Reporting
Information of the federal program:
Federal Grantor: Department of Defense (DOD)
Assistance Listing No.: 12.420, Military Medical Research and Development
Pass-Through Grantor: Johns Hopkins University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.172, Human Genome Research
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.226, Research on Healthcare Costs, Quality and Outcomes
Pass-Through Grantor: The Regents of the University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.242, Mental Health Research Grants
Pass-Through Grantor: Rutgers State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.307, Minority Health and Health Disparities Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.310, Trans-NIH Research Support
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.350, National Center for Advancing Translational Sciences
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.351, Research Infrastructure Program
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.361, Nursing Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.368, 21st Century Cures Act – Precision Medicine Initiative
Pass-Through Grantor: University of Chicago
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.394, Cancer Detection and Diagnosis Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.395, Cancer Treatment Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.396, Cancer Biology Research
Pass-Through Grantor: Tulane University, Louisiana State University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.397, Cancer Centers Support Grants
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.667, Social Services Block Grant
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.837, Cardiovascular Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.838, Lung Diseases Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.847, Diabetes, Digestive, and Kidney Diseases Extramural Research
Pass-Through Grantors: Northwestern University, Duke University, University of Washington, The Regents of University of Michigan
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.853, Extramural Research Programs in the Neurosciences and Neurological Disorders
Pass-Through Grantor: Rush University Medical Center
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.855, Allergy, Immunology and Transplantation Research
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.859, Biomedical Research and Research Training
Pass-Through Grantor: University of Wisconsin – Madison
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.865, Child Health and Human Development Extramural Research
Pass-Through Grantors: Northwestern University, University of Washington, The Regents of the University of California
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.866, Aging Research
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.946, Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs
Pass-Through Grantor: Northwestern University
Federal Grantor: United States Department of Health and Human Services (HHS)
Assistance Listing No.: 93.994, Maternal and Child Health Services Block Grant to the States
Pass-Through Grantor: Northwestern Memorial Hospital
Criteria or specific requirement (including statutory, regulatory, or other citation):
Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the auditee’s financial statements which must include the total Federal awards expended as determined in accordance with §200.502 Basis for determining Federal awards expended.”
Condition:
Certain grants related to the Research and Development Cluster were misstated by $233,405 on the preliminary schedule of expenditures of federal awards (the Schedule) provided by management due to the inappropriate classification of costs within the general ledger; the final Schedule was corrected.
In addition, an award which was not a federal grant award with expenditures of $148,388 was included on the preliminary Schedule provided by management. The final Schedule was corrected.
Cause:
Endeavor’s internal controls over the preparation of the Schedule were not sufficient to properly accumulate and accurately report all expenditures of federal awards.
Effect or Potential Effect:
Inaccurate or improper reporting of expenditures results in a misstated Schedule and can also potentially result in insufficient testing of the major programs or improper identification of major programs for audit purposes.
Questioned costs:
None.
Context:
The table below reflects the preliminary and adjusted assistance listing balances on the Schedule (only assistance listing programs which changed are included below):
Assistance Listing No. Name of Federal Program Preliminary Schedule Adjusted Schedule Change
12.420 Military Medical Research and Development $ 241,025 $ 224,418 $ 16,607
93.172 Human Genome Research 14,874 15,121 (247)
93.226 Research on Healthcare Costs, Quality and Outcomes 251,325 248,842 2,483
93.242 Mental Health Research Grants 1,616,503 1,617,376 (873)
93.307 Minority Health and Health Disparities Research 17,323 15,122 2,201
93.310 Trans-NIH Research Support 313,459 313,490 (31)
93.350 National Center for Advancing Translational Sciences 516,734 518,429 (1,695)
93.351 Research Infrastructure Program 242,436 232,058 10,378
93.361 Nursing Research 8,745 7,645 1,100
93.368 21st Century Cures Act – Precision Medicine Initiative 100,324 94,609 5,715
93.394 Cancer Detection and Diagnosis Research 847,959 816,528 31,431
93.395 Cancer Treatment Research 438,349 439,286 (937)
93.396 Cancer Biology Research 93,919 88,642 5,277
93.397 Cancer Centers Support Grants 15,552 14,078 1,474
93.667 Social Services Block Grant 19,619 27,170 (7,551)
93.837 Cardiovascular Diseases Research 193,160 188,850 4,310
93.838 Lung Diseases Research 482,934 471,427 11,507
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 1,075,493 1,035,041 40,452
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1,645,025 1,596,611 48,414
93.855 Allergy, Immunology and Transplantation Research 73,869 72,630 1,239
93.859 Biomedical Research and Research Training 363,336 366,791 (3,455)
93.865 Child Health and Human Development Extramural Research 3,790,797 3,733,008 57,789
93.866 Aging Research 1,101,363 1,098,891 2,472
93.946 Cooperative Agreements to Support State-Based Safe Motherhood and Infant Health Initiative Programs 80,039 78,033 2,006
93.994 Maternal and Child Health Services Block Grant to the States 171,995 168,656 3,339
The Role of Oral Care in Nonventilator Hospital-Acquired Pneumonia (NVHAP) Prevention 148,388 – 148,388
Total $ 13,864,545 $ 13,482,752 $ 381,793
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
Management should implement internal controls to ensure amounts are appropriately accumulated and reported on the Schedule and all federal expenditures are appropriately identified and reported on the Schedule.
Views of responsible officials:
Award amounts were changed on the Schedule after management’s review was executed. Management acknowledges that implementing the new Enterprise Resource Planning (ERP) system, in 2023 presented changes to the SEFA reporting. Management has identified and addressed the reporting issues within the new system to ensure that the grant totals are appropriately captured in the SEFA.
Endeavor will enhance grant management award processes by revising its procedures and adding additional controls to monitor for accuracy of the core data. Management will reinforce the importance of timeliness and accuracy of the Schedule reporting totals to facilitate accurate reporting.