Audit 406039

2025-002 Equipment Management Cluster: Research and Development Sponsoring Agency: All research and development cluster sponsoring agencies Award Names: All research and development cluster awards Award Numbers: All research and development cluster awards Assistance Listing Title: All research and development cluster assistance listing titles Assistance Listing Number: All research and development cluster assistance listing numbers Award Year: 2024-2025 Pass-through entity: All research and development cluster pass-through entities Criteria According to 2 CFR section 200.313, procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, at a minimum, meet the following requirements: (1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. (4) Adequate maintenance procedures must be developed to keep the property in good condition. (5) If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return. Condition The Dartmouth Health System has not completed a physical inventory of all federally purchased fixed assets at least once during the last two years. The full population of equipment funded with federal research and development dollars, as provided by the Dartmouth Health System, consisted of 10 items with a total historical cost of $186k. Cause In prior years, the Dartmouth Health System did not have a process in place to ensure that all federally funded equipment included in the fixed asset register were included in its clinical engineering database where monitoring of federally funded equipment is tracked. As a result, while the Dartmouth Health System inspected 3 federal assets in FY2024, the complete population of equipment funded with federal research and development dollars were not inspected. The Dartmouth Health system created a federal equipment tracking procedure, and updated property records to include details required by 2 CFR section 200.313, however, the inspection of all identified federal assets was not yet completed. As the corrective action plan was not fully implemented by the end of FY2025, all compliance requirements with respect to federal equipment were not yet satisfied. Effect The Dartmouth Health System's accounting records for its federally purchased fixed assets could be inaccurate as the Dartmouth Health System has not formally verified the existence, current utilization and continued need for all federally funded equipment through this physical inventory process. Questioned Costs None noted. Repeat Finding Yes. This is a repeat of finding 2022-001, 2024-004 and was reported as an open finding in the 2023 Summary Schedule of Prior Audit Findings and Status. Recommendation We recommend that the Dartmouth Health System implement a process to ensure its policies and procedures over equipment management are followed, including the performance of a physical inventory of federally purchased fixed assets at least once every two years in accordance with 2 CFR section 200.313(d)(2). Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan is included at the end of this report after the summary schedule of prior audit findings and status.

2025-001 Timeliness of Effort Certification Cluster: Research and Development (also applies to other major programs referenced below) Sponsoring Agency: All research and development cluster sponsoring agencies and Department of Health and Human Services (for the other major program referenced below) Award Names: All research and development cluster awards and Doorway for Substance Use-Related Supports and Services Award Numbers: All research and development cluster awards, Cheshire Medical Center 05-95-920510-7040000 Assistance Listing Title: All research and development cluster assistance listing titles and Opioid STR Assistance Listing Number: All research and development cluster assistance listing numbers and 93.788 Award Year: 2024-2025 Pass-through entity: All research and development cluster pass-through entities and New Hampshire Department of Health and Human Services Criteria 2 CFR 200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The Dartmouth Health System’s practice is to utilize after-the-fact effort reports to certify that compensation costs charged to federal awards, are reasonable and consistent with the work performed. Actual effort expended on each federal award is certified by a responsible person with suitable means of verification that the work was performed at the end of the specified reporting period. The Dartmouth Health System’s effort certification policy outlines the required deadlines for certifying effort reports related to federal awards. Condition In testing internal controls over effort certifications, we noted the following: · Research and development- 14 effort reports totaling $43.1k of 17 selected effort reports totaling $51.7k were certified/approved outside of allowable timeframe defined by the effort certification policy. Certifications were on average 150 days late. · 93.788- 3 effort reports totaling $8.8k of 16 selected effort reports totaling $36.5k did not include a certification/approval date to determine whether the related effort was attested within the timeframe required by the entity’s effort certification policy. Cause Individuals required to complete quarterly effort certifications did not understand the policy requirements to certify effort in a timely manner. Effect The lack of timely effort certification could result in compensation expenditures charged to federal awards that are not accurate. Questioned Costs None noted. Repeat Finding Yes. This is a repeat of finding 2024-002. Recommendation We recommend that the Dartmouth Health System recommunicate its effort certification policy and provide training to all individuals required to certify effort for federal awards to ensure that the timely approval expectations are understood and adhered to. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan is included at the end of this report after the summary schedule of prior audit findings and status.

2025-003 Suspension & Debarment Cluster: Other major program referenced below Sponsoring Agency: Department of Health and Human Services Award Names: Doorway for Substance Use-Related Supports and Services Award Numbers: Cheshire Medical Center 05-95-920510-7040000 Assistance Listing Title: Opioid STR Assistance Listing Number: 93.788 Award Year: 2024-2025 Pass-through entity: New Hampshire Department of Health and Human Services Criteria Per 2 CFR 200.214, a non-Federal entity must have and use documented procurement procedures and is prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. The Dartmouth Health System’s suspension and debarment policy requires suspension and debarment verifications to be completed for all vendors utilized on federal awards, regardless of expenditure amount. Condition In testing compliance with suspension and debarment requirements, PwC noted that 2 selections totaling $15.9k out of 9 selections tested totaling $53.5k did not have sufficient supporting documentation to evidence that required suspension and debarment procedures were completed prior to the related transaction and payment dates. For the items noted, the suspension and debarment checks were performed after the related transaction dates and payment dates. As a result, the Dartmouth Health System did not demonstrate that vendors were verified as not suspended or debarred before federal funds were disbursed. Management indicated that certain alternative verification procedures may have been performed prior to payment; however, documentation was not maintained to support that such procedures were completed timely. Cause While the Dartmouth Health System’s policy outlines the procedures to be followed for federal purchases, including required suspension and debarment checks, there was turnover within the procurement function for Cheshire Medical Center. Therefore, instances were identified in which a suspension and debarment check was not performed prior to the transaction. Effect The lack of adherence to the suspension and debarment verification policy could result in the Health System conducting business with a vendor that is suspended or debarred. Questioned Costs None noted. Repeat Finding No Recommendation We recommend the Dartmouth Health System ensure that timely suspension and debarment verifications are completed in line with policy. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan is included at the end of this report after the summary schedule of prior audit findings and status.

2025-004 Reporting Cluster: Other major program referenced below Sponsoring Agency: Department of Labor Award Names: RETAIN Demonstration Projects Award Numbers: 1947RTN2-02B Assistance Listing Title: Disability Employment Policy Development Assistance Listing Number: 17.720 Award Year: 2024-2025 Pass-through entity: Vermont Department of Labor Criteria 2 CFR 200.328 requires non-Federal entities to submit financial reports as required by the Federal award. Per the award agreement, quarterly financial reports detailing all expenses to date under the award are due no later than the fifteenth of the month being reported. Condition During testing of reporting requirements for award 17.720, we noted that monthly financial reports were submitted to the sponsoring agency; however, the required standard quarterly financial reports were not submitted. Based on communication from the sponsoring agency, although the information required for the quarterly reports was included within the monthly reports, the sponsoring agency clarified that separate quarterly reports were still required. Cause The Dartmouth Health System misunderstood the reporting requirements under the award and thought the quarterly reporting requirements were satisfied by the monthly reports submitted. Effect The Dartmouth Health System did not submit the quarterly financial reports required per the award agreement and was not in compliance with reporting requirements. Questioned Costs None noted. Repeat Finding No Recommendation The Dartmouth Health System should ensure that submission of reports is performed as stated within agreed-upon award agreements and should retroactively submit the quarterly reports that were not submitted. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan is included at the end of this report after the summary schedule of prior audit findings and status.