#2024-001: Grant Program: Department of Health and Human Services – National Institutes for Health Research and Development Cluster – Cancer Control – Assistance Listing #93.399 – Lack of Required Written Policies Condition: The Consortium does not have written policies and procedures in place as required by 2 CFR § 200.302 and § 200.313. Specifically, the Consortium lacks documented policies for: • The timing of federal cash draws; • The allowability of costs charged to federal awards; and • Documentation of time-and-effort for personal services. Criteria: 2 CFR § 200.302(b)(6)–(7) requires nonfederal entities to have written procedures for (a) cash drawdowns and (b) determining cost allowability. § 200.305 requires written cash-management procedures that minimize the time between draw and disbursement. § 200.430 requires a written policy that is consistently applied to both federal and nonfederal activities for documentation of compensation for personal services. Context: At the time of completion of the audit for the year ended May 31, 2024, the written policies were not in place. Cause: The Consortium has not yet developed or adopted the required written policies due to limited administrative capacity and reliance on informal practices. Effect: The absence of written policies increases the risk of noncompliance with federal requirements, mismanagement of federal funds, and audit findings in future periods. It may also impair the Consortium’s ability to consistently apply federal cost principles and properly safeguard assets. Recommendation: We recommend that the Consortium develop and implement written policies and procedures that comply with the requirements of Uniform Guidance. Management Response: See Corrective Action Plan.
#2024-002: Grant Program: Department of Health and Human Services – National Institutes for Health Research and Development Cluster – Cancer Control – Assistance Listing #93.599 – Lack Inadequate Documentation and Lack of Independent Review of Expenditures Condition: During the audit for the fiscal year ended May 31, 2024, transactions lacked sufficient supporting documentation or evidence of review and approval by the director. Additionally, some of the expenditures were incurred by the director and were self-reviewed without any independent oversight or secondary approval. Criteria: Per 2 CFR § 200.303, nonfederal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the organization is managing the awards in compliance with federal statutes, regulations, and the terms and conditions of the award. Effective internal controls include proper documentation and independent review of expenditures to ensure allowability, reasonableness, and compliance. Context: Out of 61 expenditures tested, 28 lacked sufficient supporting documentation or evidence of review. 21 of the 28 were expenditures incurred by the director and self-reviewed. Cause: The Consortium has not implemented adequate internal control procedures to ensure that all expenditures are properly documented and independently reviewed. The lack of segregation of duties, particularly in the review of expenditures made by the director, contributed to the deficiency. Effect: The absence of sufficient documentation and independent review increases the risk of unauthorized, unsupported, or unallowable expenditures. Recommendation: We recommend that the Consortium strengthen its internal control procedures by: • Requiring complete supporting documentation for all expenditures; • Implementing a formal review and approval process for all transactions, including those made by executive leadership; and • Ensuring that expenditures made by the director are reviewed and approved by an independent party, such as a board member or designated individual. Management Response: See Corrective Action Plan.
#2024-003: Grant Program: Department of Health and Human Services – National Institutes for Health Research and Development Cluster – Cancer Control – Assistance Listing #93.599 – Untimely Filed Data Collection Form Condition: The Consortium did not submit the Data Collection Form (DCF) and reporting package to the Federal Audit Clearinghouse (FAC) within the required timeframe for the year ended May 31, 2024. Criteria: Per 2 CFR §200.512(b), the Consortium must submit the completed DCF and the reporting package to FAC within the earlier of 30 calendar days after receipt of the Auditors’ report(s), or nine months after the end of the audit period. Context: At the time of completion of the audit for the year ended May 31, 2024, the deadline for submission of February 28, 2025, was passed and the DCF is considered not timely filed. Cause: The late submission was due to delays in finalizing the audit. Effect: Failure to submit the DCF timely may delay federal agencies’ access to audit results and could impact the Consortium’s eligibility for future funding. Additionally, an untimely filed DCF results in high-risk auditee status. Recommendation: We recommend the Consortium implement procedures to ensure timely submission of the DCF and reporting packing, including establishing internal deadlines ahead of the federal due date for audit completion. Management Response: See Corrective Action Plan.