Audit 347388

Information on the Federal Program: Federal Program: HIV - Related Training and Technical Assistance - Aids Education and Training Centers Assistance Listing: 93.145 Federal Agency: U.S. Department of Health and Human Services – Health Resources and Services Administration (HRSA) Grant Award Number: 6 U1OHA30535-08-01 Award Periods: July 1, 2023 through June 30, 2024 Pass-Through Agency: Columbia University Grant Award Number: U1SHA46532 Award Periods: September 1, 2023 through August 31, 2024 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with §200.502, Basis for determining Federal awards expended.” Condition: The Schedule of Expenditures of Federal Awards (the Schedule) did not accurately classify the HIV-Related Training and Technical Assistance – Aids Education and Training Centers program. The final Schedule was corrected for the misclassification.   Cause: The internal control over the SEFA reporting process was not operating effectively to appropriately classify grant awards on the SEFA. Effect or Potential Effect: Management included the HIV-Related Training and Technical Assistance grant (Assistance Listing 93.145) in the amount of $5,642,581 in the Research & Development (R&D) cluster. Questioned Costs: None. Context: Total R&D Cluster expenses included on the draft Schedule was $592,460,606 for the year ended June 30, 2024. Total R&D expenses included on the final Schedule were $586,818,025 for the year ended June 30, 2024. Total expenditures on the SEFA did not change. Identification as a Repeat Finding, if Applicable This is not a repeat finding. Recommendation: We recommend that management implement more robust controls to ensure accurate reporting of federal awards on the SEFA. Management’s Response: Department of Health and Human Services – Health Resources and Services Administration (HRSA) updated the award template utilizing a new federal format. Modification of this federal award template has allowed HRSA to indicate/flag (item 18 in the Notice of Grant Award - R&D “no”) whether the federal program is R&D in a manner not previously recorded or visible. This indicator flag now indicates AETC is non-R&D, therefore, we have reflected it appropriately in the FY24 SEFA. We will strengthen our controls for monitoring the cluster to ensure appropriate classification paying attention to any indications in the Notice of Grant Award.

Information on the Federal Program: Federal Program: HIV - Related Training and Technical Assistance - Aids Education and Training Centers Assistance Listing: 93.145 Federal Agency: U.S. Department of Health and Human Services – Health Resources and Services Administration (HRSA) Grant Award Number: 6 U1OHA30535-08-01 Award Periods: July 1, 2023 through June 30, 2024 Pass-Through Agency: Columbia University Grant Award Number: U1SHA46532 Award Periods: September 1, 2023 through August 31, 2024 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with §200.502, Basis for determining Federal awards expended.” Condition: The Schedule of Expenditures of Federal Awards (the Schedule) did not accurately classify the HIV-Related Training and Technical Assistance – Aids Education and Training Centers program. The final Schedule was corrected for the misclassification.   Cause: The internal control over the SEFA reporting process was not operating effectively to appropriately classify grant awards on the SEFA. Effect or Potential Effect: Management included the HIV-Related Training and Technical Assistance grant (Assistance Listing 93.145) in the amount of $5,642,581 in the Research & Development (R&D) cluster. Questioned Costs: None. Context: Total R&D Cluster expenses included on the draft Schedule was $592,460,606 for the year ended June 30, 2024. Total R&D expenses included on the final Schedule were $586,818,025 for the year ended June 30, 2024. Total expenditures on the SEFA did not change. Identification as a Repeat Finding, if Applicable This is not a repeat finding. Recommendation: We recommend that management implement more robust controls to ensure accurate reporting of federal awards on the SEFA. Management’s Response: Department of Health and Human Services – Health Resources and Services Administration (HRSA) updated the award template utilizing a new federal format. Modification of this federal award template has allowed HRSA to indicate/flag (item 18 in the Notice of Grant Award - R&D “no”) whether the federal program is R&D in a manner not previously recorded or visible. This indicator flag now indicates AETC is non-R&D, therefore, we have reflected it appropriately in the FY24 SEFA. We will strengthen our controls for monitoring the cluster to ensure appropriate classification paying attention to any indications in the Notice of Grant Award.

Information on the Federal Program: Federal Program: HIV - Related Training and Technical Assistance - Aids Education and Training Centers Assistance Listing: 93.145 Federal Agency: U.S. Department of Health and Human Services – Health Resources and Services Administration (HRSA) Grant Award Number: 6 U1OHA30535-08-01 Award Periods: July 1, 2023 through June 30, 2024 Pass-Through Agency: Columbia University Grant Award Number: U1SHA46532 Award Periods: September 1, 2023 through August 31, 2024 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with §200.502, Basis for determining Federal awards expended.” Condition: The Schedule of Expenditures of Federal Awards (the Schedule) did not accurately classify the HIV-Related Training and Technical Assistance – Aids Education and Training Centers program. The final Schedule was corrected for the misclassification.   Cause: The internal control over the SEFA reporting process was not operating effectively to appropriately classify grant awards on the SEFA. Effect or Potential Effect: Management included the HIV-Related Training and Technical Assistance grant (Assistance Listing 93.145) in the amount of $5,642,581 in the Research & Development (R&D) cluster. Questioned Costs: None. Context: Total R&D Cluster expenses included on the draft Schedule was $592,460,606 for the year ended June 30, 2024. Total R&D expenses included on the final Schedule were $586,818,025 for the year ended June 30, 2024. Total expenditures on the SEFA did not change. Identification as a Repeat Finding, if Applicable This is not a repeat finding. Recommendation: We recommend that management implement more robust controls to ensure accurate reporting of federal awards on the SEFA. Management’s Response: Department of Health and Human Services – Health Resources and Services Administration (HRSA) updated the award template utilizing a new federal format. Modification of this federal award template has allowed HRSA to indicate/flag (item 18 in the Notice of Grant Award - R&D “no”) whether the federal program is R&D in a manner not previously recorded or visible. This indicator flag now indicates AETC is non-R&D, therefore, we have reflected it appropriately in the FY24 SEFA. We will strengthen our controls for monitoring the cluster to ensure appropriate classification paying attention to any indications in the Notice of Grant Award.

Information on the Federal Program: Federal Program: HIV - Related Training and Technical Assistance - Aids Education and Training Centers Assistance Listing: 93.145 Federal Agency: U.S. Department of Health and Human Services – Health Resources and Services Administration (HRSA) Grant Award Number: 6 U1OHA30535-08-01 Award Periods: July 1, 2023 through June 30, 2024 Pass-Through Agency: Columbia University Grant Award Number: U1SHA46532 Award Periods: September 1, 2023 through August 31, 2024 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). The Uniform Guidance 2 CFR section 200.510 states, “(b) Schedule of expenditures of Federal awards. The auditee must also prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total Federal awards expended as determined in accordance with §200.502, Basis for determining Federal awards expended.” Condition: The Schedule of Expenditures of Federal Awards (the Schedule) did not accurately classify the HIV-Related Training and Technical Assistance – Aids Education and Training Centers program. The final Schedule was corrected for the misclassification.   Cause: The internal control over the SEFA reporting process was not operating effectively to appropriately classify grant awards on the SEFA. Effect or Potential Effect: Management included the HIV-Related Training and Technical Assistance grant (Assistance Listing 93.145) in the amount of $5,642,581 in the Research & Development (R&D) cluster. Questioned Costs: None. Context: Total R&D Cluster expenses included on the draft Schedule was $592,460,606 for the year ended June 30, 2024. Total R&D expenses included on the final Schedule were $586,818,025 for the year ended June 30, 2024. Total expenditures on the SEFA did not change. Identification as a Repeat Finding, if Applicable This is not a repeat finding. Recommendation: We recommend that management implement more robust controls to ensure accurate reporting of federal awards on the SEFA. Management’s Response: Department of Health and Human Services – Health Resources and Services Administration (HRSA) updated the award template utilizing a new federal format. Modification of this federal award template has allowed HRSA to indicate/flag (item 18 in the Notice of Grant Award - R&D “no”) whether the federal program is R&D in a manner not previously recorded or visible. This indicator flag now indicates AETC is non-R&D, therefore, we have reflected it appropriately in the FY24 SEFA. We will strengthen our controls for monitoring the cluster to ensure appropriate classification paying attention to any indications in the Notice of Grant Award.