Audit 323032

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-003 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.110 Maternal and Child Health Federal Consolidated Programs 2 U03MC28844-09-00 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control:   “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Effort certifications were not timely reviewed and approved consistently for all employees’ salaries and wages for the year ended December 31, 2023. Cause: The Corporation has internal controls in place to require effort certifications be approved for all employees who charge effort to the R&D Cluster. However, they are not robust enough to ensure effort certification are reviewed timely. Effect or potential effect: Effort certifications were not timely reviewed; therefore, there is a risk that inaccurately reported effort is not timely identified. Questioned costs: None Context: We tested a sample of 40 salaries and wages ($20,924) and noted two instances ($2,746) where the effort report was not reviewed timely. Total salaries and wages charged to the R&D Cluster were $35,344,051 for the year ended December 31, 2023. Section III—Federal Award Findings and Questioned Costs (continued) The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-002. Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the R&D Cluster. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. Management implemented a new procedure to ensure timely time and effort certification. Management implemented the process for first quarter 2024 to allow time for system updates and training.

Finding 2023-003 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.110 Maternal and Child Health Federal Consolidated Programs 2 U03MC28844-09-00 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control:   “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Effort certifications were not timely reviewed and approved consistently for all employees’ salaries and wages for the year ended December 31, 2023. Cause: The Corporation has internal controls in place to require effort certifications be approved for all employees who charge effort to the R&D Cluster. However, they are not robust enough to ensure effort certification are reviewed timely. Effect or potential effect: Effort certifications were not timely reviewed; therefore, there is a risk that inaccurately reported effort is not timely identified. Questioned costs: None Context: We tested a sample of 40 salaries and wages ($20,924) and noted two instances ($2,746) where the effort report was not reviewed timely. Total salaries and wages charged to the R&D Cluster were $35,344,051 for the year ended December 31, 2023. Section III—Federal Award Findings and Questioned Costs (continued) The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-002. Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the R&D Cluster. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. Management implemented a new procedure to ensure timely time and effort certification. Management implemented the process for first quarter 2024 to allow time for system updates and training.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-001 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.865 Child Health and Human Development Extramural Research 5R00HD096115-05 93.242 Mental Health Research Grants 1R01MH130437-01A1 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR078395-02 93.837 Cardiovascular Diseases Research 5R01HL157491-02 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.242 Mental Health Research Grants 1P50MH127476-01A1 93.855 Allergy and Infectious Diseases Research 5R01AI139511-05 93.838 Lung Diseases Research 5R01HL155095-03 93.855 Allergy and Infectious Diseases Research 5R01AI146581-02 93.396 Cancer Biology Research 5R01CA260178-02 93.RD MP2PRT - Cosgrove 21X121F Q2 Leidos Biomedical Research Inc 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.865 Child Health and Human Development Extramural Research 5R01HD095976-04 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research 109938-19114 University of Illinois Champaign 93.396 Cancer Biology Research 5R01CA247941-03 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.273 Alcohol Research Programs 5R01AA027502-04 93.838 Lung Diseases Research 5R01HL155095-03 93.394 Cancer Detection and Diagnosis Research 5U24CA196173-08 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 1R01NS129784-01 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.859 Biomedical Research and Research Training 5R35GM131875-05 93.855 Allergy and Infectious Diseases Research 5R01AI155501-03 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 12.420 Military Medical Research and Development W81XWH2210597 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.396 Cancer Biology Research 1R01CA260178-01A1 93.121 Oral Diseases and Disorders Research 5R01DE028296-05 93.393 Cancer Cause and Prevention Research 1R01CA272872-01 93.121 Oral Diseases and Disorders Research ULRF_21-0285-01 University of Louisville Research Foundation, Inc. 93.353 21st Century Cures Act - Beau Biden Cancer Moonshot 1U01CA232488-01 93.RD CCG-BCR HHSN261201700015I 75N91022F000 93.855 Allergy and Infectious Diseases Research 5R21AI156406-02 93.865 Child Health and Human Development Extramural Research 5R01HD100420-03 93.394 Cancer Detection and Diagnosis Research 5U24CA254445-03 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 93.394 Cancer Detection and Diagnosis Research BSB06-RAMIREZ NRG Oncology Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the 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 200.214 Suspension and Debarment “Non-Federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.” Condition: Nationwide Children’s Hospital (the Corporation) uses a third-party to perform its suspension and debarment checks on a monthly basis. However, we noted the following matters: • The Corporation did not retain the monthly supporting documentation related to the monthly suspension and debarment check. The suspension and debarment checks performed at year-end were retained. • The Corporation does not have a process to reconcile the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed to ensure the listing is complete. • The third-party vendor does not have a SOC 1 (System and Organization Controls) Report. The Corporation relied on the results of the suspension and debarment checks performed by the third-party vendor without implementing an internal process to ensure the results provided by the third-party vendor were accurate. In addition, the Corporation performs a suspension and debarment check of all new vendors prior to activating them in the procurement system. The Corporation did not consistently maintain supporting documentation to support the vendor was checked for suspension and debarment before the-“new”-vendor was set up in the procurement system. Cause: The Corporation does not have internal controls in place to require supporting documentation be maintained over the monthly suspension and debarment checks including documentation of management’s review and approval. The Corporation does not have internal controls in place to review the accuracy of third-party reports and to require a reconciliation between the vendor list sent to the third-party vendor and the results provided by the third-party vendor. The Corporation does not have internal controls in place to require supporting documentation be maintained over the suspension and debarment check performed on new vendors. Effect or potential effect: The Corporation’s vendors may not be screened for suspension and debarment, or the suspension and debarment results may not be accurate. A vendor may be set up in the procurement system that is suspended or debarred. Questioned costs: None Context: We tested a sample of 40 new vendors set up in the procurement system in 2023 and noted three instances where management did not retain the supporting documents of its review of suspension and debarment for the new vendor set up. The federal portion of procurement expenditures subject to suspension and debarment was $12,965,319 which represents approximately 12.5% of the R&D Cluster federal expenditures. The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-001. Recommendation: The Corporation should implement the following internal controls: • The monthly suspension and debarment review process • Reconciliation of the number of vendor files sent to the third-party vendor with the number of files received from the third-party vendor with the suspension and debarment results and review of the accuracy of the suspension and debarment results performed by the third-party vendor • Maintenance of the supporting documentation over the suspension and debarment checks performed on new vendors Views of responsible officials: Management agrees with the recommendation.   In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. The finding has been partially remediated. Management implemented the following remediations between Q4 2023 and Q1 2024: • Retained the monthly supporting documentation related to a monthly suspension and debarment check • Reconciled the vendor list provided to the third-party vendor with the results received from the third-party vendor after the suspension and debarment checks are performed • Verified the accuracy of the results produced by the third-party vendor • Consistently maintained supporting documentation to support the vendor was checked for suspension and debarment before the “new”-vendor is set up in the procurement system.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-002 Identification of the federal program: Federal Agency: Department of Defense and Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders P700000261 93.110 Maternal and Child Health Federal Consolidated Programs RPPN 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 5K08NS119878-02 93.225 National Research Service Awards Health Services Research Training 3201350923 93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders 2R01NS085238-06 93.394 Cancer Detection and Diagnosis Research 5UM1CA239754-04 93.846 Arthritis, Musculoskeletal and Skin Diseases Research 5R01AR073908-04 93.838 Lung Diseases Research GR110932 / SPC-1000003691 12.351 Scientific Research - Combating Weapons of Mass Destruction 60075912 93.865 Child Health and Human Development Extramural Research 5R01HD100420-04 93.350 National Center for Advancing Translational Sciences SPC-1000006837/GR127008 93.RD MP2PRT - Cosgrove GRT-00000762 The Children's Hospital of PA 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.069 Public Health Emergency Preparedness 53275 93.121 Oral Diseases and Disorders Research 5U01DE030065-02 93.361 Nursing Research 5R01NR017533-05 93.837 Cardiovascular Diseases Research 1R01HL165124-01A1 93.213 Research and Training in Complementary and Integrative Health 5R33AT009632-05 93.395 Cancer Treatment Research GR130324 93.361 Nursing Research 1R01NR020423-01A1 93.396 Cancer Biology Research GR132164 93.396 Cancer Biology Research 1R01CA260178-01A1 93.865 Child Health and Human Development Extramural Research R01HD091302 93.865 Child Health and Human Development Extramural Research 5R01HD100493-04 93.395 Cancer Treatment Research AR65349 12.420 Military Medical Research and Development GR118321 / SPC-1000004136 93.865 Child Health and Human Development Extramural Research 5R01HD074594-08 93.121 Oral Diseases and Disorders Research 5113295 93.394 Cancer Detection and Diagnosis Research BSB09-RAMIREZ 93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research S03446-01 93.127 Emergency Medical Services for Children 2 U03MC28844-09-00 93.RD BUILD BRIDGES BETTER HLTH PS1 BUILD BRIDGES BETTER HLTH PS1 93.395 Cancer Treatment Research SUB TO U10CA180886 93.RD CCG-BCR CBH-23-1506 PSA/DHHS 93.837 Cardiovascular Diseases Research 5R21HL165406-02 93.350 National Center for Advancing Translational Sciences GR133330 93.121 Oral Diseases and Disorders Research 5113295 93.855 Allergy and Infectious Diseases Research 5R01AI134848-05 93.855 Allergy and Infectious Diseases Research 5R01AI139519-05 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: There was a formula error in the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries for fiscal year 2023. Cause: The Corporation’s internal controls over the review and approval of the underlying data used to evaluate the annual fringe rate to be applied to R&D salaries was not robust enough to identify a formal error in the data utilized to evaluate the fringe rate. Effect or potential effect: The Corporation’s may determine a fringe rate that is not accurate or in accordance with their methodology. Questioned costs: None Context: Fringe expenditures within the R&D Cluster were $7,798,007 for the year end December 31, 2023. The total amount of federal expenditures reported on the Schedule for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: The Corporation review its internal controls over the fringe benefits calculation to ensure the review is more robust to include review of the underlying formulas.   Views of responsible officials: Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Management will ensure a more robust review of the underlying formulas.

Finding 2023-003 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.110 Maternal and Child Health Federal Consolidated Programs 2 U03MC28844-09-00 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control:   “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Effort certifications were not timely reviewed and approved consistently for all employees’ salaries and wages for the year ended December 31, 2023. Cause: The Corporation has internal controls in place to require effort certifications be approved for all employees who charge effort to the R&D Cluster. However, they are not robust enough to ensure effort certification are reviewed timely. Effect or potential effect: Effort certifications were not timely reviewed; therefore, there is a risk that inaccurately reported effort is not timely identified. Questioned costs: None Context: We tested a sample of 40 salaries and wages ($20,924) and noted two instances ($2,746) where the effort report was not reviewed timely. Total salaries and wages charged to the R&D Cluster were $35,344,051 for the year ended December 31, 2023. Section III—Federal Award Findings and Questioned Costs (continued) The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-002. Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the R&D Cluster. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. Management implemented a new procedure to ensure timely time and effort certification. Management implemented the process for first quarter 2024 to allow time for system updates and training.

Finding 2023-003 Identification of the federal program: Federal Agency: Department of Health and Human Services Assistance Listing No., Award Name, Award Number and Pass-Through Agency: Assistance Listing Award Name Award Number Pass-Through Agency 93.121 Oral Diseases and Disorders Research 1R01DE031756-01A1 93.110 Maternal and Child Health Federal Consolidated Programs 2 U03MC28844-09-00 Criteria or specific requirement (including statutory, regulatory, or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control:   “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ‘Standards for Internal Control in the Federal Government’ issued by the Comptroller General of the United States or the ‘Internal Control Integrated Framework,’ issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Effort certifications were not timely reviewed and approved consistently for all employees’ salaries and wages for the year ended December 31, 2023. Cause: The Corporation has internal controls in place to require effort certifications be approved for all employees who charge effort to the R&D Cluster. However, they are not robust enough to ensure effort certification are reviewed timely. Effect or potential effect: Effort certifications were not timely reviewed; therefore, there is a risk that inaccurately reported effort is not timely identified. Questioned costs: None Context: We tested a sample of 40 salaries and wages ($20,924) and noted two instances ($2,746) where the effort report was not reviewed timely. Total salaries and wages charged to the R&D Cluster were $35,344,051 for the year ended December 31, 2023. Section III—Federal Award Findings and Questioned Costs (continued) The total amount reported on the schedule of expenditures of federal awards (Schedule) for the R&D cluster is $103,660,603. Identification as a repeat finding, if applicable: This is a repeat finding; see 2022-002. Recommendation: The Corporation should review its effort certification policies and procedures and implement more robust internal controls to ensure effort certifications are approved timely for all employees charging effort to the R&D Cluster. Views of responsible officials: Management agrees with the recommendation. In September 2023, E&Y rendered the same finding and recommendation for the 2022 calendar year audit. Management implemented a new procedure to ensure timely time and effort certification. Management implemented the process for first quarter 2024 to allow time for system updates and training.