Finding Reference: 2025-001 – A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Federal Program Information Federal Agencies: Department of Justice Awards: Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: July 1, 2024 – September 30, 2026 Description: Review and Approval of Payroll Expenditures Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition The Corporation did not have appropriately designed internal controls in place over the grant subaward related to review and approval of certain payroll expenditures that were included in the Department of Justice (DOJ) submissions. Cause The Corporation did not obtain sufficient evidence of the review and approval of certain timecards and cost allocation schedules reported to the DOJ in the required submissions. Effect or potential effect The related payroll expenditures included in the DOJ submissions could be unallowed costs. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context In order to evidence review and approval of individual payroll expenditures, management reviews and approves these expenditures as part of the payroll process, specifically the review and approval of timecards and cost allocation schedules. In conjunction with our testing related to allowability, we selected a sample of payroll expenditures to test management’s review and approval of expenditures as part of the payroll process. In accordance with the Corporation’s payroll process, timecards and cost allocation schedules must be reviewed and approved for determining allowability of these payroll expenditures prior to submitting reports to the DOJ. There were six payroll expenditures totaling $5,828, or approximately 9% of our population; that did not have a timecard approval or approval of their cost allocation schedule. Based on review of the timecards and cost allocation schedules for the sample selected, no expenditures were identified as unallowable based on the terms and conditions of the grant agreement and federal program. Recommendation Management should retain documentation that evidences the review and approval of expenditures submitted to the DOJ. View of responsible officials There is no disagreement with the audit finding.
Finding Reference: 2025-002 – C. Cash Management; L. Reporting Federal Program Information Federal Agencies: Department of Health and Human Services Department of Justice Awards: Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: September 30, 2023 – September 29, 2025 July 1, 2024 – September 30, 2026 Description: Evidence of Review and Approval of the Reported Expenditures Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” The major program ALN 16.753 includes two sub-vendor contracts between the granting agency, Department of Justice (DOJ) and UMMS for the University of Maryland Medical Center (UMMC) Byrne Trauma Clinic and the University of Maryland Capital Region Medical Center (UMCAP) Byrne Discretionary Community. The major program ALN 93.078 includes two sub-vendor contracts between the granting agency, Department of Health and Human Services (DHHS) and UMMS for the ASPR Mission Zero. Condition The Corporation did not have appropriately designed internal controls in place over the grant subawards related to review and approval of the expenditures that were included in the DOJ and DHHS submissions. Cause The Corporation did not retain sufficient evidence of the review and approval of the expenditures reported to the DOJ or DHHS in the required submissions for cash reimbursement and reporting. Effect or potential effect The expenditures included in the DOJ or DHHS submissions could be inaccurate or information reported may be incomplete or untimely. Questioned costs None. Identification of a repeat finding No. This is not a repeat finding. Context For the major program ALN 16.753 quarterly cash reimbursement, quarterly financial report and semi-annual progress report submissions, management did not retain documentation to evidence review and approval of the submitted reports and expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. For the major program ALN 93.078 annual cash reimbursement and financial report, management did not retain documentation to evidence review and approval of the submitted reports and expenditures requested for cash reimbursement. Audit procedures did not identify any unallowable costs when compared to the underlying supporting documentation of the expenditure. Recommendation Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of expenditures submitted to the DOJ and DHHS for reimbursement. View of responsible officials There is no disagreement with the audit finding.
Finding Reference: 2025-003 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Health and Human Services Department of Justice Awards: Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: September 30, 2023 – September 29, 2025 July 1, 2024 – September 30, 2026 Description: Incomplete Federal Requirements within Procurement Policies Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Part 200.320 Methods of procurement to be followed states the following: “The non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319” regarding the methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have a procurement policy that conforms to all applicable standards contained in the Uniform Guidance, when purchasing goods or services with the federal funds. Cause The Corporation did not comply and maintain a procurement policy that conforms to the provisions required by the Uniform Guidance upon receiving such federal funds related to their federal programs. Effect or potential effect Purchasing of goods and/or servicing with the major federal programs may not be in compliance with the Uniform Guidance. Questioned costs None. Identification of a repeat finding This is a repeat finding of Finding 2024-006. Context Management has not established a procurement policy in line with the applicable standards contained in the Uniform Guidance based on review of the existing policy and discussions with management, however, no other instances of noncompliance with procurement standards identified in 2 CFR part 200 were noted as the amount of purchases exceeding the micro-purchase threshold was not direct and material to these programs and therefore no further testing over procurement was performed. Recommendation The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. View of responsible officials There is no disagreement with the audit finding.
Finding Reference: 2025-004 – I. Procurement, Suspension and Debarment Federal Program Information Federal Agencies: Department of Health and Human Services Department of Justice Awards: Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Award Periods: September 30, 2023 – September 29, 2025 July 1, 2024 – September 30, 2026 Description: Evidence of controls over Suspension and Debarment Criteria In accordance with Title 2 U.S. Code of Federal Regulations, Part 200.303, Internal controls, “The Non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Title 2, Subtitle A, Chapter II, Part 200, Subpart C 200.214 – Suspension and debarment – Non-Federal entities are subject to the non-procurement debarment and suspension regulations that restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Condition As part of our testing over the operating effectiveness of internal controls over the Procurement, Suspension and Debarment assertion for our major programs, we noted that the Corporation did not have appropriately designed internal controls in order to retain evidence related to the completeness and accuracy of the vendor list and monthly results for suspension and debarment. The Corporation validates that vendors are reviewed on a monthly basis to ensure they are not included on the suspension and debarment list. There was no documentation retained to support the vendor list and results were complete and accurate for the monthly validation. Cause The Corporation did not retain sufficient evidence to support the completeness and accuracy of the vendor list and results for suspension and debarment. Effect or potential effect The vendor list and monthly results for suspension and debarment may not be complete and accurate and therefore, vendors used for federally funded activities may be suspended or debarred and result in noncompliance with the requirement. Questioned costs None. Identification of a repeat finding This is a repeat finding of 2024-007. Context As part of the suspension and debarment testing, we did not identify any vendors that were excluded from the vendor list, monthly results or included within the suspension and debarment list. Management retained evidence of the monthly review including their documentation of follow ups on any vendors that required further investigation. Recommendation The Corporation should retain documentation to support completeness and accuracy of the vendor list submitted for screening and the results obtained to support the screening process to ensure that no suspended or debarred vendors are utilized by the Corporation prior to entering into transactions. View of responsible officials There is no disagreement with the audit finding.