Audit 359222

FY End
2024-09-30
Total Expended
$71.06M
Findings
4
Programs
15
Year: 2024 Accepted: 2025-06-19

Organization Exclusion Status:

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Contacts

Name Title Type
JM3QWP4D6MY1 Sergio Melgar Auditee
5083340252 Christopher Cox Auditor
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Notes to SEFA

Title: 1. Basis of Presentation Accounting Policies: The information in the accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) is presented in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and therefore, some amounts may differ from amounts presented in or used in the preparation of the UMass Memorial Health Care, Inc. and Affiliates (the System) consolidated financial statements. The purpose of the Schedule is to present a summary of those activities of the System for the year ended September 30, 2024, which have been funded by the U.S. Government (federal awards). For purposes of the Schedule, federal awards include all grants, contracts and similar federal assistance agreements entered directly between agencies and departments of the federal government and the System and federal awards passed through to the System by primary recipients of federal awards. Since the Schedule presents only a selected portion of activities of the System, it is not intended to and does not, present the balance sheet, results of operations, changes in net assets or cash flows of the System. Negative amounts reported in the Schedule represent adjustments to expenditures reported in the prior year. Assistance Listing Numbers (ALN) and agency or pass-through numbers are provided when available. De Minimis Rate Used: N Rate Explanation: The System has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance and has recovered indirect costs under certain federally funded grants for the year ended September 30, 2024 with an indirect cost rate of 16.2%. The indirect cost rate has been established by a letter dated June 6, 2021, from the System’s cognizant agency, the Department of Health and Human Services, for the effective period from October 1, 2021 through September 30, 2024. The information in the accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) is presented in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and therefore, some amounts may differ from amounts presented in or used in the preparation of the UMass Memorial Health Care, Inc. and Affiliates (the System) consolidated financial statements. The purpose of the Schedule is to present a summary of those activities of the System for the year ended September 30, 2024, which have been funded by the U.S. Government (federal awards). For purposes of the Schedule, federal awards include all grants, contracts and similar federal assistance agreements entered directly between agencies and departments of the federal government and the System and federal awards passed through to the System by primary recipients of federal awards. Since the Schedule presents only a selected portion of activities of the System, it is not intended to and does not, present the balance sheet, results of operations, changes in net assets or cash flows of the System. Negative amounts reported in the Schedule represent adjustments to expenditures reported in the prior year. Assistance Listing Numbers (ALN) and agency or pass-through numbers are provided when available.
Title: 2. Indirect Costs Accounting Policies: The information in the accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) is presented in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and therefore, some amounts may differ from amounts presented in or used in the preparation of the UMass Memorial Health Care, Inc. and Affiliates (the System) consolidated financial statements. The purpose of the Schedule is to present a summary of those activities of the System for the year ended September 30, 2024, which have been funded by the U.S. Government (federal awards). For purposes of the Schedule, federal awards include all grants, contracts and similar federal assistance agreements entered directly between agencies and departments of the federal government and the System and federal awards passed through to the System by primary recipients of federal awards. Since the Schedule presents only a selected portion of activities of the System, it is not intended to and does not, present the balance sheet, results of operations, changes in net assets or cash flows of the System. Negative amounts reported in the Schedule represent adjustments to expenditures reported in the prior year. Assistance Listing Numbers (ALN) and agency or pass-through numbers are provided when available. De Minimis Rate Used: N Rate Explanation: The System has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance and has recovered indirect costs under certain federally funded grants for the year ended September 30, 2024 with an indirect cost rate of 16.2%. The indirect cost rate has been established by a letter dated June 6, 2021, from the System’s cognizant agency, the Department of Health and Human Services, for the effective period from October 1, 2021 through September 30, 2024. The System has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance and has recovered indirect costs under certain federally funded grants for the year ended September 30, 2024 with an indirect cost rate of 16.2%. The indirect cost rate has been established by a letter dated June 6, 2021, from the System’s cognizant agency, the Department of Health and Human Services, for the effective period from October 1, 2021 through September 30, 2024.
Title: 3. Pass-Through Funds from The Commonwealth Accounting Policies: The information in the accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) is presented in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and therefore, some amounts may differ from amounts presented in or used in the preparation of the UMass Memorial Health Care, Inc. and Affiliates (the System) consolidated financial statements. The purpose of the Schedule is to present a summary of those activities of the System for the year ended September 30, 2024, which have been funded by the U.S. Government (federal awards). For purposes of the Schedule, federal awards include all grants, contracts and similar federal assistance agreements entered directly between agencies and departments of the federal government and the System and federal awards passed through to the System by primary recipients of federal awards. Since the Schedule presents only a selected portion of activities of the System, it is not intended to and does not, present the balance sheet, results of operations, changes in net assets or cash flows of the System. Negative amounts reported in the Schedule represent adjustments to expenditures reported in the prior year. Assistance Listing Numbers (ALN) and agency or pass-through numbers are provided when available. De Minimis Rate Used: N Rate Explanation: The System has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance and has recovered indirect costs under certain federally funded grants for the year ended September 30, 2024 with an indirect cost rate of 16.2%. The indirect cost rate has been established by a letter dated June 6, 2021, from the System’s cognizant agency, the Department of Health and Human Services, for the effective period from October 1, 2021 through September 30, 2024. Federal pass-through funds from The Commonwealth of Massachusetts (the “Commonwealth”) included in the Schedule totaling $6,415,361 (9% of the total expenditures of federal awards) are presented for the Commonwealth’s fiscal year (July 1, 2023 through June 30, 2024) and were taken directly from balances provided to the System by the Commonwealth. The System expended federal and non-federal pass-through funds for the period October 1, 2023 through September 30, 2024 of $10,659,849 compared to $13,236,323 for the period October 1, 2022 through September 30, 2023. Of these expenditures, the Commonwealth is unable to identify for the System what portion of the October 1, 2023 through September 30, 2024 expenditures are related to federal funding. During the period July 1, 2024 through September 30, 2024, the amount of pass-through funds expended related to the federal funding that was passed from the Commonwealth totaled $2,137,035 compared to $2,402,644 for the period from July 1, 2023 through September 30, 2023.
Title: 4. Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Accounting Policies: The information in the accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) is presented in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and therefore, some amounts may differ from amounts presented in or used in the preparation of the UMass Memorial Health Care, Inc. and Affiliates (the System) consolidated financial statements. The purpose of the Schedule is to present a summary of those activities of the System for the year ended September 30, 2024, which have been funded by the U.S. Government (federal awards). For purposes of the Schedule, federal awards include all grants, contracts and similar federal assistance agreements entered directly between agencies and departments of the federal government and the System and federal awards passed through to the System by primary recipients of federal awards. Since the Schedule presents only a selected portion of activities of the System, it is not intended to and does not, present the balance sheet, results of operations, changes in net assets or cash flows of the System. Negative amounts reported in the Schedule represent adjustments to expenditures reported in the prior year. Assistance Listing Numbers (ALN) and agency or pass-through numbers are provided when available. De Minimis Rate Used: N Rate Explanation: The System has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance and has recovered indirect costs under certain federally funded grants for the year ended September 30, 2024 with an indirect cost rate of 16.2%. The indirect cost rate has been established by a letter dated June 6, 2021, from the System’s cognizant agency, the Department of Health and Human Services, for the effective period from October 1, 2021 through September 30, 2024. In fiscal year 2024, the Special Supplemental Nutrition Program for WIC issued vouchers to program participants to be used at local grocery stores. Included in the WIC program federal expenditures is $2,711,821 which represents the value of the vouchers, which is not directly received by the System, but is included in the Schedule.
Title: 5. Federal Emergency Management Agency (FEMA) Public Assistance Accounting Policies: The information in the accompanying Schedule of Expenditures of Federal Awards (the “Schedule”) is presented in accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and therefore, some amounts may differ from amounts presented in or used in the preparation of the UMass Memorial Health Care, Inc. and Affiliates (the System) consolidated financial statements. The purpose of the Schedule is to present a summary of those activities of the System for the year ended September 30, 2024, which have been funded by the U.S. Government (federal awards). For purposes of the Schedule, federal awards include all grants, contracts and similar federal assistance agreements entered directly between agencies and departments of the federal government and the System and federal awards passed through to the System by primary recipients of federal awards. Since the Schedule presents only a selected portion of activities of the System, it is not intended to and does not, present the balance sheet, results of operations, changes in net assets or cash flows of the System. Negative amounts reported in the Schedule represent adjustments to expenditures reported in the prior year. Assistance Listing Numbers (ALN) and agency or pass-through numbers are provided when available. De Minimis Rate Used: N Rate Explanation: The System has not elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance and has recovered indirect costs under certain federally funded grants for the year ended September 30, 2024 with an indirect cost rate of 16.2%. The indirect cost rate has been established by a letter dated June 6, 2021, from the System’s cognizant agency, the Department of Health and Human Services, for the effective period from October 1, 2021 through September 30, 2024. The System applied for reimbursement of certain expenses related to the COVID-19 pandemic under Assistance Listing 97.036, FEMA Public Assistance through the Commonwealth of Massachusetts. Expenditures are reflected in the Schedule in the year in which a project application is obligated and expenses associated with those funds have been incurred. The Schedule includes $57,842,025 of expenditures incurred in fiscal years 2020, 2021, 2022, or 2023 for projects which were obligated in fiscal year 2024.

Finding Details

Finding No. 2024-001 – Procurement Award Information Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Community Project Funding/Congressionally Directed Spending - Construction Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Directives Pass-through Entity: Not applicable Criteria In accordance with 2 CFR 200.318 the entity must maintain procurement records of sufficient detail that include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. Condition In our testing, 2 of 2 samples totaling $1,874,650 were in excess of the System’s simplified acquisition threshold of $250,000. These 2 selections funded separate capital expenditures, both of which were initially funded by nonfederal dollars. Subsequently, federal earmarks were received to partially fund these projects. As such, the System did not have support that would be required for a federal purchase. More specifically, the System did not maintain support for the procurement method selected, contract type selection, contractor selection or rejection, and the basis for the contract price in accordance with 2 CFR 200.318. In addition, the 2 selections also did not have evidence maintained of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause In both circumstances, partial funding was requested to supplement larger purchases for which it was not anticipated that federal funding would be used; as such, compliance with federal funding requirements was not contemplated and thus typical support that would be required for a federal purchase was not followed. Effect The System could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None noted. Recommendation We recommend that the System update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the System’s relevant procurement thresholds is maintained consistently in the procurement files. Documentation should clearly outline the rationale for contractor selection and the System’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Finding No. 2024-001 – Procurement Award Information Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Community Project Funding/Congressionally Directed Spending - Construction Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Directives Pass-through Entity: Not applicable Criteria In accordance with 2 CFR 200.318 the entity must maintain procurement records of sufficient detail that include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. Condition In our testing, 2 of 2 samples totaling $1,874,650 were in excess of the System’s simplified acquisition threshold of $250,000. These 2 selections funded separate capital expenditures, both of which were initially funded by nonfederal dollars. Subsequently, federal earmarks were received to partially fund these projects. As such, the System did not have support that would be required for a federal purchase. More specifically, the System did not maintain support for the procurement method selected, contract type selection, contractor selection or rejection, and the basis for the contract price in accordance with 2 CFR 200.318. In addition, the 2 selections also did not have evidence maintained of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause In both circumstances, partial funding was requested to supplement larger purchases for which it was not anticipated that federal funding would be used; as such, compliance with federal funding requirements was not contemplated and thus typical support that would be required for a federal purchase was not followed. Effect The System could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None noted. Recommendation We recommend that the System update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the System’s relevant procurement thresholds is maintained consistently in the procurement files. Documentation should clearly outline the rationale for contractor selection and the System’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Finding No. 2024-001 – Procurement Award Information Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Community Project Funding/Congressionally Directed Spending - Construction Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Directives Pass-through Entity: Not applicable Criteria In accordance with 2 CFR 200.318 the entity must maintain procurement records of sufficient detail that include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. Condition In our testing, 2 of 2 samples totaling $1,874,650 were in excess of the System’s simplified acquisition threshold of $250,000. These 2 selections funded separate capital expenditures, both of which were initially funded by nonfederal dollars. Subsequently, federal earmarks were received to partially fund these projects. As such, the System did not have support that would be required for a federal purchase. More specifically, the System did not maintain support for the procurement method selected, contract type selection, contractor selection or rejection, and the basis for the contract price in accordance with 2 CFR 200.318. In addition, the 2 selections also did not have evidence maintained of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause In both circumstances, partial funding was requested to supplement larger purchases for which it was not anticipated that federal funding would be used; as such, compliance with federal funding requirements was not contemplated and thus typical support that would be required for a federal purchase was not followed. Effect The System could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None noted. Recommendation We recommend that the System update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the System’s relevant procurement thresholds is maintained consistently in the procurement files. Documentation should clearly outline the rationale for contractor selection and the System’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.
Finding No. 2024-001 – Procurement Award Information Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Community Project Funding/Congressionally Directed Spending - Construction Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Directives Pass-through Entity: Not applicable Criteria In accordance with 2 CFR 200.318 the entity must maintain procurement records of sufficient detail that include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. In accordance with 2 CFR 200.324 (a), the recipient or subrecipient must perform a cost or price analysis for every procurement transaction, including contract modifications, in excess of the simplified acquisition threshold. Condition In our testing, 2 of 2 samples totaling $1,874,650 were in excess of the System’s simplified acquisition threshold of $250,000. These 2 selections funded separate capital expenditures, both of which were initially funded by nonfederal dollars. Subsequently, federal earmarks were received to partially fund these projects. As such, the System did not have support that would be required for a federal purchase. More specifically, the System did not maintain support for the procurement method selected, contract type selection, contractor selection or rejection, and the basis for the contract price in accordance with 2 CFR 200.318. In addition, the 2 selections also did not have evidence maintained of an independent cost or price analysis in accordance with CFR 200.324 (a). Cause In both circumstances, partial funding was requested to supplement larger purchases for which it was not anticipated that federal funding would be used; as such, compliance with federal funding requirements was not contemplated and thus typical support that would be required for a federal purchase was not followed. Effect The System could be entering into transactions which are not the most economical or practical procurements for the Federal Government and such transaction could be unallowed or result in unallowable costs. Questioned Costs None noted. Recommendation We recommend that the System update its procurement policy so that contemporaneous documentation and retention of evidence for the selection of each vendor that meets the System’s relevant procurement thresholds is maintained consistently in the procurement files. Documentation should clearly outline the rationale for contractor selection and the System’s independent cost or price analysis. Management’s Views and Corrective Action Plan Management’s views and corrective action plan is included at the end of this report.