FAC Explorer

Audit 363769

FY End
2024-12-31
Total Expended
$511.68M
Findings
552
Programs
76
Organization: Mayo Clinic (MN)
Year: 2024 Accepted: 2025-08-06
Auditor: Ernst & Young LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
572657 2024-002 Significant Deficiency - C
572658 2024-003 Material Weakness Yes M
572659 2024-002 Significant Deficiency - C
572660 2024-002 Significant Deficiency - C
572661 2024-002 Significant Deficiency - C
572662 2024-002 Significant Deficiency - C
572663 2024-002 Significant Deficiency - C
572664 2024-003 Material Weakness Yes M
572665 2024-002 Significant Deficiency - C
572666 2024-003 Material Weakness Yes M
572667 2024-002 Significant Deficiency - C
572668 2024-002 Significant Deficiency - C
572669 2024-002 Significant Deficiency - C
572670 2024-002 Significant Deficiency - C
572671 2024-002 Significant Deficiency - C
572672 2024-002 Significant Deficiency - C
572673 2024-002 Significant Deficiency - C
572674 2024-002 Significant Deficiency - C
572675 2024-002 Significant Deficiency - C
572676 2024-002 Significant Deficiency - C
572677 2024-002 Significant Deficiency - C
572678 2024-002 Significant Deficiency - C
572679 2024-002 Significant Deficiency - C
572680 2024-002 Significant Deficiency - C
572681 2024-002 Significant Deficiency - C
572682 2024-002 Significant Deficiency - C
572683 2024-002 Significant Deficiency - C
572684 2024-002 Significant Deficiency - C
572685 2024-002 Significant Deficiency - C
572686 2024-002 Significant Deficiency - C
572687 2024-002 Significant Deficiency - C
572688 2024-002 Significant Deficiency - C
572689 2024-002 Significant Deficiency - C
572690 2024-002 Significant Deficiency - C
572691 2024-002 Significant Deficiency - C
572692 2024-002 Significant Deficiency - C
572693 2024-002 Significant Deficiency - C
572694 2024-002 Significant Deficiency - C
572695 2024-002 Significant Deficiency - C
572696 2024-003 Material Weakness Yes M
572697 2024-002 Significant Deficiency - C
572698 2024-003 Material Weakness Yes M
572699 2024-002 Significant Deficiency - C
572700 2024-003 Material Weakness Yes M
572701 2024-002 Significant Deficiency - C
572702 2024-002 Significant Deficiency - C
572703 2024-003 Material Weakness Yes M
572704 2024-002 Significant Deficiency - C
572705 2024-002 Significant Deficiency - C
572706 2024-002 Significant Deficiency - C
572707 2024-003 Material Weakness Yes M
572708 2024-002 Significant Deficiency - C
572709 2024-002 Significant Deficiency - C
572710 2024-002 Significant Deficiency - C
572711 2024-002 Significant Deficiency - C
572712 2024-003 Material Weakness Yes M
572713 2024-002 Significant Deficiency - C
572714 2024-003 Material Weakness Yes M
572715 2024-002 Significant Deficiency - C
572716 2024-002 Significant Deficiency - C
572717 2024-003 Material Weakness Yes M
572718 2024-002 Significant Deficiency - C
572719 2024-003 Material Weakness Yes M
572720 2024-002 Significant Deficiency - C
572721 2024-003 Material Weakness Yes M
572722 2024-002 Significant Deficiency - C
572723 2024-002 Significant Deficiency - C
572724 2024-002 Significant Deficiency - C
572725 2024-002 Significant Deficiency - C
572726 2024-002 Significant Deficiency - C
572727 2024-002 Significant Deficiency - C
572728 2024-002 Significant Deficiency - C
572729 2024-002 Significant Deficiency - C
572730 2024-003 Material Weakness Yes M
572731 2024-002 Significant Deficiency - C
572732 2024-002 Significant Deficiency - C
572733 2024-003 Material Weakness Yes M
572734 2024-002 Significant Deficiency - C
572735 2024-002 Significant Deficiency - C
572736 2024-002 Significant Deficiency - C
572737 2024-002 Significant Deficiency - C
572738 2024-002 Significant Deficiency - C
572739 2024-002 Significant Deficiency - C
572740 2024-003 Material Weakness Yes M
572741 2024-002 Significant Deficiency - C
572742 2024-002 Significant Deficiency - C
572743 2024-002 Significant Deficiency - C
572744 2024-002 Significant Deficiency - C
572745 2024-002 Significant Deficiency - C
572746 2024-002 Significant Deficiency - C
572747 2024-002 Significant Deficiency - C
572748 2024-002 Significant Deficiency - C
572749 2024-002 Significant Deficiency - C
572750 2024-002 Significant Deficiency - C
572751 2024-002 Significant Deficiency - C
572752 2024-002 Significant Deficiency - C
572753 2024-002 Significant Deficiency - C
572754 2024-002 Significant Deficiency - C
572755 2024-002 Significant Deficiency - C
572756 2024-003 Material Weakness Yes M
572757 2024-002 Significant Deficiency - C
572758 2024-003 Material Weakness Yes M
572759 2024-002 Significant Deficiency - C
572760 2024-003 Material Weakness Yes M
572761 2024-002 Significant Deficiency - C
572762 2024-002 Significant Deficiency - C
572763 2024-002 Significant Deficiency - C
572764 2024-003 Material Weakness Yes M
572765 2024-002 Significant Deficiency - C
572766 2024-002 Significant Deficiency - C
572767 2024-002 Significant Deficiency - C
572768 2024-003 Material Weakness Yes M
572769 2024-002 Significant Deficiency - C
572770 2024-003 Material Weakness Yes M
572771 2024-002 Significant Deficiency - C
572772 2024-002 Significant Deficiency - C
572773 2024-002 Significant Deficiency - C
572774 2024-002 Significant Deficiency - C
572775 2024-002 Significant Deficiency - C
572776 2024-002 Significant Deficiency - C
572777 2024-002 Significant Deficiency - C
572778 2024-002 Significant Deficiency - C
572779 2024-002 Significant Deficiency - C
572780 2024-002 Significant Deficiency - C
572781 2024-002 Significant Deficiency - C
572782 2024-003 Material Weakness Yes M
572783 2024-002 Significant Deficiency - C
572784 2024-003 Material Weakness Yes M
572785 2024-002 Significant Deficiency - C
572786 2024-002 Significant Deficiency - C
572787 2024-002 Significant Deficiency - C
572788 2024-002 Significant Deficiency - C
572789 2024-002 Significant Deficiency - C
572790 2024-002 Significant Deficiency - C
572791 2024-002 Significant Deficiency - C
572792 2024-002 Significant Deficiency - C
572793 2024-002 Significant Deficiency - C
572794 2024-002 Significant Deficiency - C
572795 2024-002 Significant Deficiency - C
572796 2024-002 Significant Deficiency - C
572797 2024-003 Material Weakness Yes M
572798 2024-002 Significant Deficiency - C
572799 2024-002 Significant Deficiency - C
572800 2024-002 Significant Deficiency - C
572801 2024-002 Significant Deficiency - C
572802 2024-002 Significant Deficiency - C
572803 2024-003 Material Weakness Yes M
572804 2024-002 Significant Deficiency - C
572805 2024-002 Significant Deficiency - C
572806 2024-002 Significant Deficiency - C
572807 2024-003 Material Weakness Yes M
572808 2024-002 Significant Deficiency - C
572809 2024-002 Significant Deficiency - C
572810 2024-002 Significant Deficiency - C
572811 2024-002 Significant Deficiency - C
572812 2024-002 Significant Deficiency - C
572813 2024-002 Significant Deficiency - C
572814 2024-002 Significant Deficiency - C
572815 2024-002 Significant Deficiency - C
572816 2024-002 Significant Deficiency - C
572817 2024-002 Significant Deficiency - C
572818 2024-002 Significant Deficiency - C
572819 2024-002 Significant Deficiency - C
572820 2024-002 Significant Deficiency - C
572821 2024-003 Material Weakness Yes M
572822 2024-002 Significant Deficiency - C
572823 2024-002 Significant Deficiency - C
572824 2024-002 Significant Deficiency - C
572825 2024-002 Significant Deficiency - C
572826 2024-003 Material Weakness Yes M
572827 2024-002 Significant Deficiency - C
572828 2024-002 Significant Deficiency - C
572829 2024-002 Significant Deficiency - C
572830 2024-003 Material Weakness Yes M
572831 2024-002 Significant Deficiency - C
572832 2024-002 Significant Deficiency - C
572833 2024-002 Significant Deficiency - C
572834 2024-003 Material Weakness Yes M
572835 2024-002 Significant Deficiency - C
572836 2024-002 Significant Deficiency - C
572837 2024-003 Material Weakness Yes M
572838 2024-002 Significant Deficiency - C
572839 2024-002 Significant Deficiency - C
572840 2024-002 Significant Deficiency - C
572841 2024-002 Significant Deficiency - C
572842 2024-002 Significant Deficiency - C
572843 2024-002 Significant Deficiency - C
572844 2024-003 Material Weakness Yes M
572845 2024-002 Significant Deficiency - C
572846 2024-002 Significant Deficiency - C
572847 2024-002 Significant Deficiency - C
572848 2024-003 Material Weakness Yes M
572849 2024-002 Significant Deficiency - C
572850 2024-002 Significant Deficiency - C
572851 2024-003 Material Weakness Yes M
572852 2024-002 Significant Deficiency - C
572853 2024-003 Material Weakness Yes M
572854 2024-002 Significant Deficiency - C
572855 2024-002 Significant Deficiency - C
572856 2024-002 Significant Deficiency - C
572857 2024-003 Material Weakness Yes M
572858 2024-002 Significant Deficiency - C
572859 2024-002 Significant Deficiency - C
572860 2024-003 Material Weakness Yes M
572861 2024-002 Significant Deficiency - C
572862 2024-002 Significant Deficiency - C
572863 2024-002 Significant Deficiency - C
572864 2024-002 Significant Deficiency - C
572865 2024-002 Significant Deficiency - C
572866 2024-002 Significant Deficiency - C
572867 2024-002 Significant Deficiency - C
572868 2024-003 Material Weakness Yes M
572869 2024-002 Significant Deficiency - C
572870 2024-002 Significant Deficiency - C
572871 2024-002 Significant Deficiency - C
572872 2024-002 Significant Deficiency - C
572873 2024-002 Significant Deficiency - C
572874 2024-003 Material Weakness Yes M
572875 2024-002 Significant Deficiency - C
572876 2024-002 Significant Deficiency - C
572877 2024-003 Material Weakness Yes M
572878 2024-002 Significant Deficiency - C
572879 2024-002 Significant Deficiency - C
572880 2024-002 Significant Deficiency - C
572881 2024-002 Significant Deficiency - C
572882 2024-002 Significant Deficiency - C
572883 2024-002 Significant Deficiency - C
572884 2024-002 Significant Deficiency - C
572885 2024-002 Significant Deficiency - C
572886 2024-002 Significant Deficiency - C
572887 2024-003 Material Weakness Yes M
572888 2024-002 Significant Deficiency - C
572889 2024-002 Significant Deficiency - C
572890 2024-002 Significant Deficiency - C
572891 2024-003 Material Weakness Yes M
572892 2024-002 Significant Deficiency - C
572893 2024-002 Significant Deficiency - C
572894 2024-002 Significant Deficiency - C
572895 2024-002 Significant Deficiency - C
572896 2024-003 Material Weakness Yes M
572897 2024-002 Significant Deficiency - C
572898 2024-002 Significant Deficiency - C
572899 2024-003 Material Weakness Yes M
572900 2024-002 Significant Deficiency - C
572901 2024-002 Significant Deficiency - C
572902 2024-002 Significant Deficiency - C
572903 2024-003 Material Weakness Yes M
572904 2024-002 Significant Deficiency - C
572905 2024-002 Significant Deficiency - C
572906 2024-002 Significant Deficiency - C
572907 2024-002 Significant Deficiency - C
572908 2024-002 Significant Deficiency - C
572909 2024-003 Material Weakness Yes M
572910 2024-002 Significant Deficiency - C
572911 2024-002 Significant Deficiency - C
572912 2024-003 Material Weakness Yes M
572913 2024-002 Significant Deficiency - C
572914 2024-003 Material Weakness Yes M
572915 2024-002 Significant Deficiency - C
572916 2024-003 Material Weakness Yes M
572917 2024-002 Significant Deficiency - C
572918 2024-003 Material Weakness Yes M
572919 2024-002 Significant Deficiency - C
572920 2024-002 Significant Deficiency - C
572921 2024-002 Significant Deficiency - C
572922 2024-002 Significant Deficiency - C
572923 2024-002 Significant Deficiency - C
572924 2024-003 Material Weakness Yes M
572925 2024-002 Significant Deficiency - C
572926 2024-002 Significant Deficiency - C
572927 2024-002 Significant Deficiency - C
572928 2024-003 Material Weakness Yes M
572929 2024-002 Significant Deficiency - C
572930 2024-002 Significant Deficiency - C
572931 2024-002 Significant Deficiency - C
572932 2024-002 Significant Deficiency - C
1149099 2024-002 Significant Deficiency - C
1149100 2024-003 Material Weakness Yes M
1149101 2024-002 Significant Deficiency - C
1149102 2024-002 Significant Deficiency - C
1149103 2024-002 Significant Deficiency - C
1149104 2024-002 Significant Deficiency - C
1149105 2024-002 Significant Deficiency - C
1149106 2024-003 Material Weakness Yes M
1149107 2024-002 Significant Deficiency - C
1149108 2024-003 Material Weakness Yes M
1149109 2024-002 Significant Deficiency - C
1149110 2024-002 Significant Deficiency - C
1149111 2024-002 Significant Deficiency - C
1149112 2024-002 Significant Deficiency - C
1149113 2024-002 Significant Deficiency - C
1149114 2024-002 Significant Deficiency - C
1149115 2024-002 Significant Deficiency - C
1149116 2024-002 Significant Deficiency - C
1149117 2024-002 Significant Deficiency - C
1149118 2024-002 Significant Deficiency - C
1149119 2024-002 Significant Deficiency - C
1149120 2024-002 Significant Deficiency - C
1149121 2024-002 Significant Deficiency - C
1149122 2024-002 Significant Deficiency - C
1149123 2024-002 Significant Deficiency - C
1149124 2024-002 Significant Deficiency - C
1149125 2024-002 Significant Deficiency - C
1149126 2024-002 Significant Deficiency - C
1149127 2024-002 Significant Deficiency - C
1149128 2024-002 Significant Deficiency - C
1149129 2024-002 Significant Deficiency - C
1149130 2024-002 Significant Deficiency - C
1149131 2024-002 Significant Deficiency - C
1149132 2024-002 Significant Deficiency - C
1149133 2024-002 Significant Deficiency - C
1149134 2024-002 Significant Deficiency - C
1149135 2024-002 Significant Deficiency - C
1149136 2024-002 Significant Deficiency - C
1149137 2024-002 Significant Deficiency - C
1149138 2024-003 Material Weakness Yes M
1149139 2024-002 Significant Deficiency - C
1149140 2024-003 Material Weakness Yes M
1149141 2024-002 Significant Deficiency - C
1149142 2024-003 Material Weakness Yes M
1149143 2024-002 Significant Deficiency - C
1149144 2024-002 Significant Deficiency - C
1149145 2024-003 Material Weakness Yes M
1149146 2024-002 Significant Deficiency - C
1149147 2024-002 Significant Deficiency - C
1149148 2024-002 Significant Deficiency - C
1149149 2024-003 Material Weakness Yes M
1149150 2024-002 Significant Deficiency - C
1149151 2024-002 Significant Deficiency - C
1149152 2024-002 Significant Deficiency - C
1149153 2024-002 Significant Deficiency - C
1149154 2024-003 Material Weakness Yes M
1149155 2024-002 Significant Deficiency - C
1149156 2024-003 Material Weakness Yes M
1149157 2024-002 Significant Deficiency - C
1149158 2024-002 Significant Deficiency - C
1149159 2024-003 Material Weakness Yes M
1149160 2024-002 Significant Deficiency - C
1149161 2024-003 Material Weakness Yes M
1149162 2024-002 Significant Deficiency - C
1149163 2024-003 Material Weakness Yes M
1149164 2024-002 Significant Deficiency - C
1149165 2024-002 Significant Deficiency - C
1149166 2024-002 Significant Deficiency - C
1149167 2024-002 Significant Deficiency - C
1149168 2024-002 Significant Deficiency - C
1149169 2024-002 Significant Deficiency - C
1149170 2024-002 Significant Deficiency - C
1149171 2024-002 Significant Deficiency - C
1149172 2024-003 Material Weakness Yes M
1149173 2024-002 Significant Deficiency - C
1149174 2024-002 Significant Deficiency - C
1149175 2024-003 Material Weakness Yes M
1149176 2024-002 Significant Deficiency - C
1149177 2024-002 Significant Deficiency - C
1149178 2024-002 Significant Deficiency - C
1149179 2024-002 Significant Deficiency - C
1149180 2024-002 Significant Deficiency - C
1149181 2024-002 Significant Deficiency - C
1149182 2024-003 Material Weakness Yes M
1149183 2024-002 Significant Deficiency - C
1149184 2024-002 Significant Deficiency - C
1149185 2024-002 Significant Deficiency - C
1149186 2024-002 Significant Deficiency - C
1149187 2024-002 Significant Deficiency - C
1149188 2024-002 Significant Deficiency - C
1149189 2024-002 Significant Deficiency - C
1149190 2024-002 Significant Deficiency - C
1149191 2024-002 Significant Deficiency - C
1149192 2024-002 Significant Deficiency - C
1149193 2024-002 Significant Deficiency - C
1149194 2024-002 Significant Deficiency - C
1149195 2024-002 Significant Deficiency - C
1149196 2024-002 Significant Deficiency - C
1149197 2024-002 Significant Deficiency - C
1149198 2024-003 Material Weakness Yes M
1149199 2024-002 Significant Deficiency - C
1149200 2024-003 Material Weakness Yes M
1149201 2024-002 Significant Deficiency - C
1149202 2024-003 Material Weakness Yes M
1149203 2024-002 Significant Deficiency - C
1149204 2024-002 Significant Deficiency - C
1149205 2024-002 Significant Deficiency - C
1149206 2024-003 Material Weakness Yes M
1149207 2024-002 Significant Deficiency - C
1149208 2024-002 Significant Deficiency - C
1149209 2024-002 Significant Deficiency - C
1149210 2024-003 Material Weakness Yes M
1149211 2024-002 Significant Deficiency - C
1149212 2024-003 Material Weakness Yes M
1149213 2024-002 Significant Deficiency - C
1149214 2024-002 Significant Deficiency - C
1149215 2024-002 Significant Deficiency - C
1149216 2024-002 Significant Deficiency - C
1149217 2024-002 Significant Deficiency - C
1149218 2024-002 Significant Deficiency - C
1149219 2024-002 Significant Deficiency - C
1149220 2024-002 Significant Deficiency - C
1149221 2024-002 Significant Deficiency - C
1149222 2024-002 Significant Deficiency - C
1149223 2024-002 Significant Deficiency - C
1149224 2024-003 Material Weakness Yes M
1149225 2024-002 Significant Deficiency - C
1149226 2024-003 Material Weakness Yes M
1149227 2024-002 Significant Deficiency - C
1149228 2024-002 Significant Deficiency - C
1149229 2024-002 Significant Deficiency - C
1149230 2024-002 Significant Deficiency - C
1149231 2024-002 Significant Deficiency - C
1149232 2024-002 Significant Deficiency - C
1149233 2024-002 Significant Deficiency - C
1149234 2024-002 Significant Deficiency - C
1149235 2024-002 Significant Deficiency - C
1149236 2024-002 Significant Deficiency - C
1149237 2024-002 Significant Deficiency - C
1149238 2024-002 Significant Deficiency - C
1149239 2024-003 Material Weakness Yes M
1149240 2024-002 Significant Deficiency - C
1149241 2024-002 Significant Deficiency - C
1149242 2024-002 Significant Deficiency - C
1149243 2024-002 Significant Deficiency - C
1149244 2024-002 Significant Deficiency - C
1149245 2024-003 Material Weakness Yes M
1149246 2024-002 Significant Deficiency - C
1149247 2024-002 Significant Deficiency - C
1149248 2024-002 Significant Deficiency - C
1149249 2024-003 Material Weakness Yes M
1149250 2024-002 Significant Deficiency - C
1149251 2024-002 Significant Deficiency - C
1149252 2024-002 Significant Deficiency - C
1149253 2024-002 Significant Deficiency - C
1149254 2024-002 Significant Deficiency - C
1149255 2024-002 Significant Deficiency - C
1149256 2024-002 Significant Deficiency - C
1149257 2024-002 Significant Deficiency - C
1149258 2024-002 Significant Deficiency - C
1149259 2024-002 Significant Deficiency - C
1149260 2024-002 Significant Deficiency - C
1149261 2024-002 Significant Deficiency - C
1149262 2024-002 Significant Deficiency - C
1149263 2024-003 Material Weakness Yes M
1149264 2024-002 Significant Deficiency - C
1149265 2024-002 Significant Deficiency - C
1149266 2024-002 Significant Deficiency - C
1149267 2024-002 Significant Deficiency - C
1149268 2024-003 Material Weakness Yes M
1149269 2024-002 Significant Deficiency - C
1149270 2024-002 Significant Deficiency - C
1149271 2024-002 Significant Deficiency - C
1149272 2024-003 Material Weakness Yes M
1149273 2024-002 Significant Deficiency - C
1149274 2024-002 Significant Deficiency - C
1149275 2024-002 Significant Deficiency - C
1149276 2024-003 Material Weakness Yes M
1149277 2024-002 Significant Deficiency - C
1149278 2024-002 Significant Deficiency - C
1149279 2024-003 Material Weakness Yes M
1149280 2024-002 Significant Deficiency - C
1149281 2024-002 Significant Deficiency - C
1149282 2024-002 Significant Deficiency - C
1149283 2024-002 Significant Deficiency - C
1149284 2024-002 Significant Deficiency - C
1149285 2024-002 Significant Deficiency - C
1149286 2024-003 Material Weakness Yes M
1149287 2024-002 Significant Deficiency - C
1149288 2024-002 Significant Deficiency - C
1149289 2024-002 Significant Deficiency - C
1149290 2024-003 Material Weakness Yes M
1149291 2024-002 Significant Deficiency - C
1149292 2024-002 Significant Deficiency - C
1149293 2024-003 Material Weakness Yes M
1149294 2024-002 Significant Deficiency - C
1149295 2024-003 Material Weakness Yes M
1149296 2024-002 Significant Deficiency - C
1149297 2024-002 Significant Deficiency - C
1149298 2024-002 Significant Deficiency - C
1149299 2024-003 Material Weakness Yes M
1149300 2024-002 Significant Deficiency - C
1149301 2024-002 Significant Deficiency - C
1149302 2024-003 Material Weakness Yes M
1149303 2024-002 Significant Deficiency - C
1149304 2024-002 Significant Deficiency - C
1149305 2024-002 Significant Deficiency - C
1149306 2024-002 Significant Deficiency - C
1149307 2024-002 Significant Deficiency - C
1149308 2024-002 Significant Deficiency - C
1149309 2024-002 Significant Deficiency - C
1149310 2024-003 Material Weakness Yes M
1149311 2024-002 Significant Deficiency - C
1149312 2024-002 Significant Deficiency - C
1149313 2024-002 Significant Deficiency - C
1149314 2024-002 Significant Deficiency - C
1149315 2024-002 Significant Deficiency - C
1149316 2024-003 Material Weakness Yes M
1149317 2024-002 Significant Deficiency - C
1149318 2024-002 Significant Deficiency - C
1149319 2024-003 Material Weakness Yes M
1149320 2024-002 Significant Deficiency - C
1149321 2024-002 Significant Deficiency - C
1149322 2024-002 Significant Deficiency - C
1149323 2024-002 Significant Deficiency - C
1149324 2024-002 Significant Deficiency - C
1149325 2024-002 Significant Deficiency - C
1149326 2024-002 Significant Deficiency - C
1149327 2024-002 Significant Deficiency - C
1149328 2024-002 Significant Deficiency - C
1149329 2024-003 Material Weakness Yes M
1149330 2024-002 Significant Deficiency - C
1149331 2024-002 Significant Deficiency - C
1149332 2024-002 Significant Deficiency - C
1149333 2024-003 Material Weakness Yes M
1149334 2024-002 Significant Deficiency - C
1149335 2024-002 Significant Deficiency - C
1149336 2024-002 Significant Deficiency - C
1149337 2024-002 Significant Deficiency - C
1149338 2024-003 Material Weakness Yes M
1149339 2024-002 Significant Deficiency - C
1149340 2024-002 Significant Deficiency - C
1149341 2024-003 Material Weakness Yes M
1149342 2024-002 Significant Deficiency - C
1149343 2024-002 Significant Deficiency - C
1149344 2024-002 Significant Deficiency - C
1149345 2024-003 Material Weakness Yes M
1149346 2024-002 Significant Deficiency - C
1149347 2024-002 Significant Deficiency - C
1149348 2024-002 Significant Deficiency - C
1149349 2024-002 Significant Deficiency - C
1149350 2024-002 Significant Deficiency - C
1149351 2024-003 Material Weakness Yes M
1149352 2024-002 Significant Deficiency - C
1149353 2024-002 Significant Deficiency - C
1149354 2024-003 Material Weakness Yes M
1149355 2024-002 Significant Deficiency - C
1149356 2024-003 Material Weakness Yes M
1149357 2024-002 Significant Deficiency - C
1149358 2024-003 Material Weakness Yes M
1149359 2024-002 Significant Deficiency - C
1149360 2024-003 Material Weakness Yes M
1149361 2024-002 Significant Deficiency - C
1149362 2024-002 Significant Deficiency - C
1149363 2024-002 Significant Deficiency - C
1149364 2024-002 Significant Deficiency - C
1149365 2024-002 Significant Deficiency - C
1149366 2024-003 Material Weakness Yes M
1149367 2024-002 Significant Deficiency - C
1149368 2024-002 Significant Deficiency - C
1149369 2024-002 Significant Deficiency - C
1149370 2024-003 Material Weakness Yes M
1149371 2024-002 Significant Deficiency - C
1149372 2024-002 Significant Deficiency - C
1149373 2024-002 Significant Deficiency - C
1149374 2024-002 Significant Deficiency - C

Programs

ALN Program Spent Major Findings
84.268 Federal Direct Student Loans $17.72M - 0
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $2.16M - 0
93.398 Cancer Research Manpower $880,129 Yes 0
93.068 Chronic Diseases: Research, Control, and Prevention $816,489 Yes 0
93.838 Lung Diseases Research $672,260 Yes 0
93.279 Drug Abuse and Addiction Research Programs $648,040 Yes 2
12.300 Basic and Applied Scientific Research $624,690 Yes 0
93.837 Cardiovascular Diseases Research $481,449 Yes 0
93.226 Research on Healthcare Costs, Quality and Outcomes $453,757 Yes 0
93.867 Vision Research $435,071 Yes 1
93.889 National Bioterrorism Hospital Preparedness Program $419,302 - 0
93.273 Alcohol Research Programs $406,128 Yes 0
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $336,750 Yes 0
93.855 Allergy and Infectious Diseases Research $319,502 Yes 0
93.213 Research and Training in Complementary and Integrative Health $297,702 Yes 0
93.859 Biomedical Research and Research Training $278,599 Yes 0
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $278,309 Yes 0
93.351 Research Infrastructure Programs $235,697 Yes 0
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $223,106 Yes 2
43.001 Science $206,470 Yes 0
93.865 Child Health and Human Development Extramural Research $204,220 Yes 0
93.397 Cancer Centers Support Grants $200,583 Yes 0
93.879 Medical Library Assistance $198,318 Yes 0
93.361 Nursing Research $195,728 Yes 1
12.910 Research and Technology Development $190,662 Yes 0
93.U01 Military Health Professions Scholarships $172,334 - 0
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $163,783 Yes 0
12.750 Uniformed Services University Medical Research Projects $157,281 Yes 0
93.393 Cancer Cause and Prevention Research $153,975 Yes 0
14.157 Supportive Housing for the Elderly $141,205 - 0
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $135,825 Yes 0
93.396 Cancer Biology Research $122,456 Yes 0
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $116,120 Yes 0
93.399 Cancer Control $115,716 Yes 0
93.RD Contract $114,919 Yes 0
93.268 Immunization Cooperative Agreements $107,829 - 0
93.083 Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases $107,349 Yes 0
93.384 Advanced Research Projects Agency for Health (arpa-H) $97,191 Yes 0
93.823 Public Health Response, Forecasting, and Analytic Capacities Related to Disease Outbreaks, Epidemics, and Pandemics $84,329 Yes 0
93.113 Environmental Health $83,650 Yes 0
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $83,014 Yes 0
47.070 Computer and Information Science and Engineering $82,676 Yes 0
93.947 Tuberculosis Demonstration, Research, Public and Professional Education $81,326 Yes 0
93.242 Mental Health Research Grants $78,846 Yes 0
93.350 National Center for Advancing Translational Sciences $78,380 Yes 0
93.307 Minority Health and Health Disparities Research $73,615 Yes 0
10.310 Agriculture and Food Research Initiative (afri) $72,194 Yes 0
12.RD Contract $70,936 Yes 0
47.076 Stem Education (formerly Education and Human Resources) $61,935 Yes 0
84.063 Federal Pell Grant Program $57,320 - 0
14.871 Section 8 Housing Choice Vouchers $55,175 - 0
93.395 Cancer Treatment Research $47,151 Yes 0
47.041 Engineering $43,802 Yes 0
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $38,586 Yes 0
64.RD Contract $38,555 Yes 0
47.084 Nsf Technology, Innovation, and Partnerships $33,621 Yes 0
47.049 Mathematical and Physical Sciences $30,194 Yes 0
93.110 Maternal and Child Health Federal Consolidated Programs $27,949 Yes 0
16.575 Crime Victim Assistance $26,008 - 0
93.866 Aging Research $25,275 Yes 0
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $24,050 Yes 0
47.074 Biological Sciences $23,728 Yes 0
93.233 National Center on Sleep Disorders Research $22,076 Yes 0
93.134 Grants to Increase Organ Donation $19,003 Yes 0
93.103 Food and Drug Administration Research $14,122 Yes 0
12.420 Military Medical Research and Development $14,110 Yes 0
93.121 Oral Diseases and Disorders Research $10,190 Yes 0
93.173 Research Related to Deafness and Communication Disorders $9,270 Yes 0
93.172 Human Genome Research $8,639 Yes 0
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $7,573 Yes 0
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $5,389 Yes 0
93.394 Cancer Detection and Diagnosis Research $5,388 Yes 0
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $1,161 Yes 0
93.839 Blood Diseases and Resources Research $577 Yes 0
93.310 Trans-Nih Research Support $427 Yes 0
93.917 Hiv Care Formula Grants $104 Yes 0

Contacts

Name Title Type
Y2K4F9RPRRG7 Susan Norby Auditee
5072845773 Karthik Ramaswamy Auditor
No contacts on file

Notes to SEFA

Title: 1. Significant Accounting Policies Accounting Policies: The accompanying Schedules of Expenditures of Federal Awards and Florida State Financial Assistance (the Schedules) include the federal and Florida state grant activity of Mayo Clinic (the Clinic) under programs of the federal and Florida state government for the year ended December 31, 2024. The information in the Schedules is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), and Chapter 10.650, Rules of the Auditor General of the State of Florida. Because the Schedules only present a selected portion of the operations of the Clinic, they are not intended to, and do not, present the consolidated financial position, results of operations, or cash flows of the Clinic. Expenditures reported in the Schedules are reported on the cash basis of accounting, except for the Student Financial Assistance Cluster, which are reported on the accrual basis of accounting. Under the cash basis, expenditures are recognized when paid rather than when the obligation is incurred. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts reported on the Schedules represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: Y Rate Explanation: Indirect cost rates for Mayo are based on applicable U.S. Department of Health and Human Services negotiated rates, the 10% de minimis indirect cost rate allowed by the Uniform Guidance, or sponsor-specific (capped) rates. The accompanying Schedules of Expenditures of Federal Awards and Florida State Financial Assistance (the Schedules) include the federal and Florida state grant activity of Mayo Clinic (the Clinic) under programs of the federal and Florida state government for the year ended December 31, 2024. The information in the Schedules is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), and Chapter 10.650, Rules of the Auditor General of the State of Florida. Because the Schedules only present a selected portion of the operations of the Clinic, they are not intended to, and do not, present the consolidated financial position, results of operations, or cash flows of the Clinic. Expenditures reported in the Schedules are reported on the cash basis of accounting, except for the Student Financial Assistance Cluster, which are reported on the accrual basis of accounting. Under the cash basis, expenditures are recognized when paid rather than when the obligation is incurred. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts reported on the Schedules represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years.
Title: 2. 10% De Minimis Cost Rate Accounting Policies: The accompanying Schedules of Expenditures of Federal Awards and Florida State Financial Assistance (the Schedules) include the federal and Florida state grant activity of Mayo Clinic (the Clinic) under programs of the federal and Florida state government for the year ended December 31, 2024. The information in the Schedules is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), and Chapter 10.650, Rules of the Auditor General of the State of Florida. Because the Schedules only present a selected portion of the operations of the Clinic, they are not intended to, and do not, present the consolidated financial position, results of operations, or cash flows of the Clinic. Expenditures reported in the Schedules are reported on the cash basis of accounting, except for the Student Financial Assistance Cluster, which are reported on the accrual basis of accounting. Under the cash basis, expenditures are recognized when paid rather than when the obligation is incurred. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts reported on the Schedules represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: Y Rate Explanation: Indirect cost rates for Mayo are based on applicable U.S. Department of Health and Human Services negotiated rates, the 10% de minimis indirect cost rate allowed by the Uniform Guidance, or sponsor-specific (capped) rates. Indirect cost rates for Mayo are based on applicable U.S. Department of Health and Human Services negotiated rates, the 10% de minimis indirect cost rate allowed by the Uniform Guidance, or sponsor-specific (capped) rates.
Title: 3. Section 202 Direct Loans and Federal Direct Loans Accounting Policies: The accompanying Schedules of Expenditures of Federal Awards and Florida State Financial Assistance (the Schedules) include the federal and Florida state grant activity of Mayo Clinic (the Clinic) under programs of the federal and Florida state government for the year ended December 31, 2024. The information in the Schedules is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), and Chapter 10.650, Rules of the Auditor General of the State of Florida. Because the Schedules only present a selected portion of the operations of the Clinic, they are not intended to, and do not, present the consolidated financial position, results of operations, or cash flows of the Clinic. Expenditures reported in the Schedules are reported on the cash basis of accounting, except for the Student Financial Assistance Cluster, which are reported on the accrual basis of accounting. Under the cash basis, expenditures are recognized when paid rather than when the obligation is incurred. Such expenditures are reported following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts reported on the Schedules represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: Y Rate Explanation: Indirect cost rates for Mayo are based on applicable U.S. Department of Health and Human Services negotiated rates, the 10% de minimis indirect cost rate allowed by the Uniform Guidance, or sponsor-specific (capped) rates. The Supportive Housing for the Elderly, Section 202 Direct Loans program (Assistance Listing No. 14.157), is considered a federal award until the outstanding balance is paid in full. At December 31, 2024, Bloomer Lakeview, Inc.’s outstanding balance is $87,921. During the year, the Clinic expended $17,718,352 in Federal Direct Student Loans (Assistance Listing No. 84.268), which includes Direct Stafford Loans and Parent Loans for Undergraduate Students from the federal government. The federal government is responsible for billings and collections of the loans. The Clinic assists the federal government by processing the applications and applying funds to student accounts from the federal government. Since this program is administered by the federal government, new loans made in the fiscal year ended December 31, 2024, related to Federal Direct Student Loans are considered current year federal expenditures, whereas the outstanding loan balances are not.

Finding Details

Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-003
Subrecipient Monitoring Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 93.279, 93.286, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, and 93.866 Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Section 200.332(c) of the Uniform Guidance states: “Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a pass-through entity should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; Section III – Federal Award and State Project Findings and Questioned Costs (continued) (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency).” Section 200.332(e) of the Uniform Guidance states: “Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports.” Furthermore, it is the Clinic’s policy for principal investigators to complete a subaward monitoring checklist as part of the monthly/quarterly reviews of subrecipient performance. Condition: Required subrecipient monitoring activities were not consistently performed related to annual subrecipient risk assessments. In addition, subaward monitoring checklists were not consistently completed or retained to evidence the results of the monitoring performed over subrecipients by principal investigators during the fiscal year. Cause: Established internal controls over the completion of annual risk assessments and completion of the subaward monitoring checklist as part of the monthly/quarterly subrecipient financial reviews were not followed during the fiscal year. Effect or potential effect: Subrecipients may not be monitored timely. A subaward may not be used for authorized purposes, or performance goals may not be achieved by the subrecipient. Questioned costs: None. Context: We sampled 35 subrecipients (totaling $18,118,028 in federal expenditures) and noted that for 23 subrecipients (totaling $14,057,672 in federal expenditures), the Clinic did not complete its annual risk assessment and review of subrecipient audit monitoring activities during fiscal year 2024, as required. We sampled 40 subaward monitoring checklists required to be completed during fiscal year 2024 by various principal investigators and noted in two instances (5%) the subaward monitoring checklist was not completed. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is a partial repeat of Finding 2023-003 from the prior year. Recommendation: The Clinic should ensure that the annual subrecipient risk assessments and subrecipient monitoring checklists are completed timely and documentation is retained to support the operating effectiveness of established internal controls. Views of responsible officials: As described in Finding 2024-002, the report used for subrecipient risk assessments were delayed due to the necessary rebuilding of report. All risk assessments are now current and monitoring is in place to ensure it remains sustainable and compliant. Further, control processes for subrecipients monitoring checklists have been modified to ensure complete and timely documentation is retained.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.
Finding 2024-002
Cash Management Identification of the federal program: Federal Agencies: U.S. Department of Health and Human Services, U.S. Department of Defense and National Science Foundation. Federal Cluster: Research and Development (R&D) Assistance Listing Nos.: 12.300, 12.420, 12.RDC, 47.070, 93.350, 93.840, 93.121, 93.172, 93.173, 93.226, 93.242, 93.273, 93.279, 93.286, 93.353, 93.361, 93.393, 93.394, 93.395, 93.396, 93.397, 93.837, 93.838, 93.839, 93.846, 93.847, 93.853, 93.855, 93.859, 93.865, 93.866, 93.867, and 93.RD Award Numbers: Various Award Periods: Various Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government,” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: The Clinic did not perform its monthly review control timely related to payments made to subrecipients. Cause: The development of new internal reports related to subrecipient payments caused a delay in the performance of the internal control during the fiscal year. Effect or potential effect: Untimely review of subrecipient payments may not timely detect payments to subrecipients that may not be made in accordance with the subaward agreement and not timely identify any cash management violations by the subrecipients such as not minimizing the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of such funds by the subrecipients. Questioned costs: None. Context: During fiscal year 2024, the timing of the monthly review control performed was as follows: • Payments made during the months of January–May 2024 were reviewed in July 2024. • Payments made in June 2024 were reviewed in November 2024. • Payments made during the months of July–November 2024 were reviewed in January 2025. • December 2024 payments were reviewed in March 2025. Subrecipient expenditures are $55,501,945, representing 11.3% of total Federal expenditures for the R&D Cluster of $490,180,429 for the year ended December 31, 2024. Identification as a repeat finding, if applicable: This finding is not a repeat finding from the prior year. Recommendation: Management should ensure timely review of subrecipient payments based on the established internal controls and policies. Views of responsible officials: Reviews were delayed due to the necessary rebuilding of reports to fully support the monthly monitoring process. All reviews are now current, and monitoring is in place to ensure it remains sustainable and compliant.