2024-001: Suspension and Debarment Control Design Deficiency
Grantor: Department of the Treasury
Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Award Name: American Rescue Plan Act (“ARPA”) - Coronavirus State Fiscal Recovery Fund and Coronavirus
Local Fiscal Recovery Fund, Coronavirus State and Local Fiscal Recovery Funds (HVIP)
Award Numbers: GRT000755, GRT000759
Assistance Listing Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Years: May 1, 2023 – December 31, 2024, July 1, 2023 – September 30, 2024
Passthrough Entities: Baltimore City Health Department, Mayor and City Council of Baltimore
Criteria
Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established
procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the
transaction.
Condition
JHHS did not have robust procedures and controls in place from Q1 through Q3 FY2024 to ensure that an
upfront suspension and debarment check was performed on all external vendors prior to entering into a covered
transaction with JHHS.
Cause
Since 2018, JHHS has relied on a third-party service provider, PaymentWorks, to perform suspension and
debarment checks on external vendors, which requires a setup process to be completed by the vendor. There
were some vendors that did not complete setup in PaymentWorks, for which management did not perform a
separate suspension and debarment check manually. Starting in Q4 2024, management implemented a
quarterly control procedure to reconcile all vendors with expenditures in the federal grant cost center to the
PaymentWorks listing to identify vendors for which a manual suspension and debarment check must be
performed.
Effect
There was a period of time, Q1 through Q3, in which JHHS may have entered into covered transactions with
suspended or debarred entities. When management performed the new control in Q4 2024, they identified 11
vendors that had not been previously reviewed and performed a manual check for suspension and debarment
via Sam.gov. None of these 11 vendors manually checked were suspended or debarred. There were no
instances of noncompliance identified as a result of this control design deficiency in our FY2024 audit work.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should continue the quarterly process of reconciling the complete vendor listing with PaymentWorks to
ensure all necessary vendors are reviewed for suspension and debarment prior to entering into covered
transactions.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-001: Suspension and Debarment Control Design Deficiency
Grantor: Department of the Treasury
Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Award Name: American Rescue Plan Act (“ARPA”) - Coronavirus State Fiscal Recovery Fund and Coronavirus
Local Fiscal Recovery Fund, Coronavirus State and Local Fiscal Recovery Funds (HVIP)
Award Numbers: GRT000755, GRT000759
Assistance Listing Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Years: May 1, 2023 – December 31, 2024, July 1, 2023 – September 30, 2024
Passthrough Entities: Baltimore City Health Department, Mayor and City Council of Baltimore
Criteria
Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established
procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the
transaction.
Condition
JHHS did not have robust procedures and controls in place from Q1 through Q3 FY2024 to ensure that an
upfront suspension and debarment check was performed on all external vendors prior to entering into a covered
transaction with JHHS.
Cause
Since 2018, JHHS has relied on a third-party service provider, PaymentWorks, to perform suspension and
debarment checks on external vendors, which requires a setup process to be completed by the vendor. There
were some vendors that did not complete setup in PaymentWorks, for which management did not perform a
separate suspension and debarment check manually. Starting in Q4 2024, management implemented a
quarterly control procedure to reconcile all vendors with expenditures in the federal grant cost center to the
PaymentWorks listing to identify vendors for which a manual suspension and debarment check must be
performed.
Effect
There was a period of time, Q1 through Q3, in which JHHS may have entered into covered transactions with
suspended or debarred entities. When management performed the new control in Q4 2024, they identified 11
vendors that had not been previously reviewed and performed a manual check for suspension and debarment
via Sam.gov. None of these 11 vendors manually checked were suspended or debarred. There were no
instances of noncompliance identified as a result of this control design deficiency in our FY2024 audit work.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should continue the quarterly process of reconciling the complete vendor listing with PaymentWorks to
ensure all necessary vendors are reviewed for suspension and debarment prior to entering into covered
transactions.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-002: Healthy Start Fringe Rate
Grantor: Department of Health and Human Services
Program Title: Healthy Start Initiative
Award Name: Healthy Start Initiative‐Eliminating Racial/Ethnic Disparities
Award Number: H4927805
Assistance Listing Title: Healthy Start Initiative
Assistance Listing Number: 93.926
Award Year: April 1, 2023 – August 31, 2024
Passthrough Entity: None
Criteria
Per 2 CFR 200.431(c), the cost of fringe benefits are allowable provided that the benefits are reasonable.
Condition
Per the Johns Hopkins All Children's Hospital, Inc. Hospital Rate Agreement dated 12/23/2022, the agreedupon fringe rate was 27% for the period 7/1/2022 to 6/30/2026. JHHS charged costs for fringe benefits to the
award at the rate of 29% during the 2024 fiscal year.
Cause
Since the Notice of Award #4H49MC27805-10-05 stated that up to 25% of the total approved budget may be
reallocated within the approved categories without prior approval, management believed they were allowed to
charge fringe costs at a rate higher than the agreed-upon negotiated rate if the difference in cost did not exceed
25% of the budget.
Effect
JHHS charged $5,906 of additional fringe costs to the award in excess of the agreed-upon negotiated rate.
Questioned Costs
The $5,906 of additional fringe charged to this award in excess of agreed-upon fringe rate is a questioned cost.
Recommendation
JHHS should establish a process to ensure that the appropriate or agreed-upon negotiated fringe rate is being
used, unless the award agreement allows for any modification of the negotiated rate or prior agency approval is
obtained.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-003: Healthy Start Procurement Compliance and Control Deficiency
Grantor: Department of Health and Human Services
Program Title: Healthy Start Initiative
Award Name: Healthy Start Initiative‐Eliminating Racial/Ethnic Disparities
Award Number: H4927805
Assistance Listing Title: Healthy Start Initiative
Assistance Listing Number: 93.926
Award Year: April 1, 2023 – August 31, 2024
Passthrough Entity: None
Criteria
Per 2 CFR 200.318-320, the auditee must maintain and use documented procedures for procurement
transactions under a Federal award, including that procurement transactions must be conducted in a manner
that provides full and open competition.
Condition
In accordance with JHHS’ Competitive Bidding Policy dated 5/5/2020, competitive bidding must be performed
for all purchases under federal grants that exceed $3,000. JHHS’ policy has three exceptions: 1) emergency
procurements, 2) compatible product requirements, which includes an option for the completion of a sole source
justification memo, and 3) recently bid products/ services. For 2 of 2 procurement selections tested during the
audit for the Healthy Start Initiative award, no evidence was found that competitive bidding procedures were
followed in accordance with JHHS policy.
Cause
There was no control operating to ensure adherence to JHHS’s Competitive Bidding Policy on competitive
bidding or sole source justification requirements prior to entering into a procurement transaction.
Effect
JHHS was not in compliance with federal requirements relating to procurement and two transactions were
entered into without full and open competition.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should establish a control process to ensure that all required competitive bidding or sole source
justification requirements are followed including review and approval prior to entering into procurement
transactions, and evidence of such review and approval is maintained. JHHS should also ensure appropriate
training and communication is shared with all departments responsible for managing federal grant programs to
ensure adherence to federal requirements and with JHHS policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-004: Use of Expired Federally Negotiated Rate
Grantor: Department of Health and Human Services, National Institute of Health (NIH)/ National Institute on
Drug Abuse
Cluster: Research & Development
Award Name: Clinical Support Services for the Research Efforts of the Stroke Branch, Section on Stroke
Diagnostics and Therapeutics, NINDS, NIH
Award Number: 75N95019C00074
Assistance Listing Title: National Institute of Neurological Disorders & Stroke Direct Award
Assistance Listing Number: 93.RD
Award Year: September 28, 2019 – September 27, 2024
Passthrough Entity: None
Criteria
In accordance with Section 2(c) of OMB Uniform Guidance Appendix IV to Part 200—Indirect (F&A) Costs
Identification and Assignment, and Rate Determination for Nonprofit Organizations, organizations that have
previously established indirect cost rates must submit a new indirect cost proposal to the cognizant agency for
indirect costs within six months after the close of each fiscal year.
Condition
JHHS had a federally negotiated indirect cost rate agreement for the period 7/1/2015- 6/30/2019, which had an
approved rate of 39.5%. An extension of the rate was granted through 6/30/2021, but the new indirect cost rate
proposal has not been accepted. In FY24, JHHS continued to charge indirect costs to the National Institute of
Neurological Disorders & Stroke Direct Award using this rate, despite the fact that this rate had expired.
Cause
As a result of JHHS staff turnover, management failed to finalize the new federally negotiated indirect cost rate
in a timely manner. Rate negotiations are currently in progress.
Effect
JHHS has charged $145,295 of indirect costs to this award, which has been approved for reimbursement by the
granting agency, but is using an expired rate agreement.
Questioned Costs
There are no questioned costs associated with this finding. JHHS has continued to use the historically accepted
rate during the ongoing negotiations.
Recommendation
JHHS should establish control procedures to ensure that the indirect cost rates used are related to approved
and effective rate agreements. Management should also ensure submitted rate proposals are approved in a
timely manner such that there is no lapse in rate agreements or a provisional rate is established during periods
of rate negotiations.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-006: Return of Interest Earned on Advance Payment Cash Receipts
Grantor: Department of Health and Human Services (DHHS)
Program Title: Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities
Award Name: Region 3 Emerging Special Pathogen Treatment Center at The Johns Hopkins Hospital (JH
Biocontainment Unit)
Award Number: U3REP220674
Assistance Listing Title: Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities
Assistance Listing Number: 93.817
Award Year: September 30, 2023 – September 29, 2024
Passthrough Entity: None
Criteria
Per 2 CFR 200.305(b)(11)-(12), the auditee must maintain advance payments of Federal funds in interestbearing accounts and may retain up to $500 per year of interest earned on Federal funds to use for
administrative expenses of the recipient or subrecipient. Any additional interest earned on Federal funds must
be returned annually to the DHHS Payment Management System (PMS).
Condition
JHHS received advance payments from DHHS for the HPP award totaling $1,615,384 in October 2023, which
were maintained in an interest-bearing account and disbursed over the period through September 2024. During
the fiscal year ended 6/30/2024, JHHS earned $51,620 of interest, which was not returned to DHHS.
Cause
Management was not aware of the requirement to return interest earned on advance payments in excess of
$500.
Effect
Management did not perform a calculation of interest earned and return the interest earned to DHHS at least
annually, as required.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should return the interest earned to DHHS as required, and establish a process to ensure that interest on
advance payments received from federal agencies is calculated at least annually and returned appropriately if
interest earned is in excess of $500.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-001: Suspension and Debarment Control Design Deficiency
Grantor: Department of the Treasury
Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Award Name: American Rescue Plan Act (“ARPA”) - Coronavirus State Fiscal Recovery Fund and Coronavirus
Local Fiscal Recovery Fund, Coronavirus State and Local Fiscal Recovery Funds (HVIP)
Award Numbers: GRT000755, GRT000759
Assistance Listing Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Years: May 1, 2023 – December 31, 2024, July 1, 2023 – September 30, 2024
Passthrough Entities: Baltimore City Health Department, Mayor and City Council of Baltimore
Criteria
Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established
procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the
transaction.
Condition
JHHS did not have robust procedures and controls in place from Q1 through Q3 FY2024 to ensure that an
upfront suspension and debarment check was performed on all external vendors prior to entering into a covered
transaction with JHHS.
Cause
Since 2018, JHHS has relied on a third-party service provider, PaymentWorks, to perform suspension and
debarment checks on external vendors, which requires a setup process to be completed by the vendor. There
were some vendors that did not complete setup in PaymentWorks, for which management did not perform a
separate suspension and debarment check manually. Starting in Q4 2024, management implemented a
quarterly control procedure to reconcile all vendors with expenditures in the federal grant cost center to the
PaymentWorks listing to identify vendors for which a manual suspension and debarment check must be
performed.
Effect
There was a period of time, Q1 through Q3, in which JHHS may have entered into covered transactions with
suspended or debarred entities. When management performed the new control in Q4 2024, they identified 11
vendors that had not been previously reviewed and performed a manual check for suspension and debarment
via Sam.gov. None of these 11 vendors manually checked were suspended or debarred. There were no
instances of noncompliance identified as a result of this control design deficiency in our FY2024 audit work.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should continue the quarterly process of reconciling the complete vendor listing with PaymentWorks to
ensure all necessary vendors are reviewed for suspension and debarment prior to entering into covered
transactions.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-001: Suspension and Debarment Control Design Deficiency
Grantor: Department of the Treasury
Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Award Name: American Rescue Plan Act (“ARPA”) - Coronavirus State Fiscal Recovery Fund and Coronavirus
Local Fiscal Recovery Fund, Coronavirus State and Local Fiscal Recovery Funds (HVIP)
Award Numbers: GRT000755, GRT000759
Assistance Listing Titles: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Award Years: May 1, 2023 – December 31, 2024, July 1, 2023 – September 30, 2024
Passthrough Entities: Baltimore City Health Department, Mayor and City Council of Baltimore
Criteria
Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established
procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the
transaction.
Condition
JHHS did not have robust procedures and controls in place from Q1 through Q3 FY2024 to ensure that an
upfront suspension and debarment check was performed on all external vendors prior to entering into a covered
transaction with JHHS.
Cause
Since 2018, JHHS has relied on a third-party service provider, PaymentWorks, to perform suspension and
debarment checks on external vendors, which requires a setup process to be completed by the vendor. There
were some vendors that did not complete setup in PaymentWorks, for which management did not perform a
separate suspension and debarment check manually. Starting in Q4 2024, management implemented a
quarterly control procedure to reconcile all vendors with expenditures in the federal grant cost center to the
PaymentWorks listing to identify vendors for which a manual suspension and debarment check must be
performed.
Effect
There was a period of time, Q1 through Q3, in which JHHS may have entered into covered transactions with
suspended or debarred entities. When management performed the new control in Q4 2024, they identified 11
vendors that had not been previously reviewed and performed a manual check for suspension and debarment
via Sam.gov. None of these 11 vendors manually checked were suspended or debarred. There were no
instances of noncompliance identified as a result of this control design deficiency in our FY2024 audit work.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should continue the quarterly process of reconciling the complete vendor listing with PaymentWorks to
ensure all necessary vendors are reviewed for suspension and debarment prior to entering into covered
transactions.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-002: Healthy Start Fringe Rate
Grantor: Department of Health and Human Services
Program Title: Healthy Start Initiative
Award Name: Healthy Start Initiative‐Eliminating Racial/Ethnic Disparities
Award Number: H4927805
Assistance Listing Title: Healthy Start Initiative
Assistance Listing Number: 93.926
Award Year: April 1, 2023 – August 31, 2024
Passthrough Entity: None
Criteria
Per 2 CFR 200.431(c), the cost of fringe benefits are allowable provided that the benefits are reasonable.
Condition
Per the Johns Hopkins All Children's Hospital, Inc. Hospital Rate Agreement dated 12/23/2022, the agreedupon fringe rate was 27% for the period 7/1/2022 to 6/30/2026. JHHS charged costs for fringe benefits to the
award at the rate of 29% during the 2024 fiscal year.
Cause
Since the Notice of Award #4H49MC27805-10-05 stated that up to 25% of the total approved budget may be
reallocated within the approved categories without prior approval, management believed they were allowed to
charge fringe costs at a rate higher than the agreed-upon negotiated rate if the difference in cost did not exceed
25% of the budget.
Effect
JHHS charged $5,906 of additional fringe costs to the award in excess of the agreed-upon negotiated rate.
Questioned Costs
The $5,906 of additional fringe charged to this award in excess of agreed-upon fringe rate is a questioned cost.
Recommendation
JHHS should establish a process to ensure that the appropriate or agreed-upon negotiated fringe rate is being
used, unless the award agreement allows for any modification of the negotiated rate or prior agency approval is
obtained.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-003: Healthy Start Procurement Compliance and Control Deficiency
Grantor: Department of Health and Human Services
Program Title: Healthy Start Initiative
Award Name: Healthy Start Initiative‐Eliminating Racial/Ethnic Disparities
Award Number: H4927805
Assistance Listing Title: Healthy Start Initiative
Assistance Listing Number: 93.926
Award Year: April 1, 2023 – August 31, 2024
Passthrough Entity: None
Criteria
Per 2 CFR 200.318-320, the auditee must maintain and use documented procedures for procurement
transactions under a Federal award, including that procurement transactions must be conducted in a manner
that provides full and open competition.
Condition
In accordance with JHHS’ Competitive Bidding Policy dated 5/5/2020, competitive bidding must be performed
for all purchases under federal grants that exceed $3,000. JHHS’ policy has three exceptions: 1) emergency
procurements, 2) compatible product requirements, which includes an option for the completion of a sole source
justification memo, and 3) recently bid products/ services. For 2 of 2 procurement selections tested during the
audit for the Healthy Start Initiative award, no evidence was found that competitive bidding procedures were
followed in accordance with JHHS policy.
Cause
There was no control operating to ensure adherence to JHHS’s Competitive Bidding Policy on competitive
bidding or sole source justification requirements prior to entering into a procurement transaction.
Effect
JHHS was not in compliance with federal requirements relating to procurement and two transactions were
entered into without full and open competition.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should establish a control process to ensure that all required competitive bidding or sole source
justification requirements are followed including review and approval prior to entering into procurement
transactions, and evidence of such review and approval is maintained. JHHS should also ensure appropriate
training and communication is shared with all departments responsible for managing federal grant programs to
ensure adherence to federal requirements and with JHHS policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-004: Use of Expired Federally Negotiated Rate
Grantor: Department of Health and Human Services, National Institute of Health (NIH)/ National Institute on
Drug Abuse
Cluster: Research & Development
Award Name: Clinical Support Services for the Research Efforts of the Stroke Branch, Section on Stroke
Diagnostics and Therapeutics, NINDS, NIH
Award Number: 75N95019C00074
Assistance Listing Title: National Institute of Neurological Disorders & Stroke Direct Award
Assistance Listing Number: 93.RD
Award Year: September 28, 2019 – September 27, 2024
Passthrough Entity: None
Criteria
In accordance with Section 2(c) of OMB Uniform Guidance Appendix IV to Part 200—Indirect (F&A) Costs
Identification and Assignment, and Rate Determination for Nonprofit Organizations, organizations that have
previously established indirect cost rates must submit a new indirect cost proposal to the cognizant agency for
indirect costs within six months after the close of each fiscal year.
Condition
JHHS had a federally negotiated indirect cost rate agreement for the period 7/1/2015- 6/30/2019, which had an
approved rate of 39.5%. An extension of the rate was granted through 6/30/2021, but the new indirect cost rate
proposal has not been accepted. In FY24, JHHS continued to charge indirect costs to the National Institute of
Neurological Disorders & Stroke Direct Award using this rate, despite the fact that this rate had expired.
Cause
As a result of JHHS staff turnover, management failed to finalize the new federally negotiated indirect cost rate
in a timely manner. Rate negotiations are currently in progress.
Effect
JHHS has charged $145,295 of indirect costs to this award, which has been approved for reimbursement by the
granting agency, but is using an expired rate agreement.
Questioned Costs
There are no questioned costs associated with this finding. JHHS has continued to use the historically accepted
rate during the ongoing negotiations.
Recommendation
JHHS should establish control procedures to ensure that the indirect cost rates used are related to approved
and effective rate agreements. Management should also ensure submitted rate proposals are approved in a
timely manner such that there is no lapse in rate agreements or a provisional rate is established during periods
of rate negotiations.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.
2024-006: Return of Interest Earned on Advance Payment Cash Receipts
Grantor: Department of Health and Human Services (DHHS)
Program Title: Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities
Award Name: Region 3 Emerging Special Pathogen Treatment Center at The Johns Hopkins Hospital (JH
Biocontainment Unit)
Award Number: U3REP220674
Assistance Listing Title: Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities
Assistance Listing Number: 93.817
Award Year: September 30, 2023 – September 29, 2024
Passthrough Entity: None
Criteria
Per 2 CFR 200.305(b)(11)-(12), the auditee must maintain advance payments of Federal funds in interestbearing accounts and may retain up to $500 per year of interest earned on Federal funds to use for
administrative expenses of the recipient or subrecipient. Any additional interest earned on Federal funds must
be returned annually to the DHHS Payment Management System (PMS).
Condition
JHHS received advance payments from DHHS for the HPP award totaling $1,615,384 in October 2023, which
were maintained in an interest-bearing account and disbursed over the period through September 2024. During
the fiscal year ended 6/30/2024, JHHS earned $51,620 of interest, which was not returned to DHHS.
Cause
Management was not aware of the requirement to return interest earned on advance payments in excess of
$500.
Effect
Management did not perform a calculation of interest earned and return the interest earned to DHHS at least
annually, as required.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
JHHS should return the interest earned to DHHS as required, and establish a process to ensure that interest on
advance payments received from federal agencies is calculated at least annually and returned appropriately if
interest earned is in excess of $500.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.