Reporting Information of the federal program: Federal Grantor: U.S. Department of Health and Human Services Federal Cluster: None Assistance Listing No.: 93.912, Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement Federal Award Numbers: G42RH50050 Federal Award Periods: September 1, 2023 through August 31, 2027 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Under the Federal Funding Accountability and Transparency Act (FFATA), Public Law 109-282, as implemented in Title 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, recipients of grants or cooperative agreements who make first-tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subaward data, such as the subaward date, subawardee Unique Entity Identifier number, amount of subaward, subaward obligation/action date, date of report submission, and subaward number, are submitted through the FSRS and accessible to the general public through the USASpending.gov website. Reports are required to be submitted by the end of the month following the subaward date. Condition: During our testing of UPMC’s reporting, it was identified that two of the FFATA reports were not submitted within the timeframe designated by 2 CFR 170 Appendix A. (See the Notes to the SEFA for chart/table.) Furthermore, evidence of review and approval of the FFATA reports and Federal Financial Reports required to be reported under were not maintained. Cause: Policies and procedures and internal controls were in place but not consistently operating across the UPMC health system to ensure compliance with the reporting requirements under the Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement (Assistance Listing No. 93.912). Effect or potential effect: The timing deficiency noted in the FFATA reporting process resulted in noncompliance with federal regulations. Furthermore, though it does not appear that inappropriate information was transmitted on the FFATA reports, this could occur if appropriate controls are not documented and functioning properly. Questioned costs: None. Context: Total subrecipient expenditures subject to FFATA reporting were $229,691 and total federal expenditures for Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement (Assistance Listing No. 93.912) were $1,865,588 for the year ended December 31, 2025. Total federal expenditures for the year ended December 31, 2025, were $45,791,146. Identification as a repeat finding, if applicable: No. Recommendation: UPMC should ensure all control policies related to the reporting compliance processes are operating consistently across the UPMC health system and that evidence of each control is maintained. We recommend UPMC maintain a tracking log of subawards and FFATA reports to ensure they are submitted within the required timeframe. Views of responsible officials: Management concurs with this finding.
FFATA Reporting Information of the federal program: Federal Grantor: U.S. Department of Health and Human Services Federal Cluster: None Assistance Listing No.: 93.243, Substance Abuse and Mental Health Services Projects of Regional and National Significance Federal Award Number: H79SP083245 Federal Award Period: September 30, 2024, through September 29, 2029 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Under the Federal Funding Accountability and Transparency Act (FFATA), Public Law 109-282, as implemented in Title 2 CFR Part 170, Reporting Subaward and Executive Compensation Information, recipients of grants or cooperative agreements who make first-tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Subaward data, such as the subaward date, subawardee Unique Entity Identifier number, amount of subaward, subaward obligation/action date, date of report submission, and subaward number, are submitted through the FSRS and accessible to the general public through the USASpending.gov website. Reports are required to be submitted by the end of the month following the subaward date. Condition: During our testing of UPMC’s reporting, it was identified that two of the FFATA reports were not submitted within the timeframe designated by 2 CFR 170 Appendix A. (See the Notes to the SEFA for chart/table.) Furthermore, evidence of review and approval of the FFATA reports and Federal Financial Reports required to be reported under were not maintained. Cause: Policies and procedures and internal controls were in place but not consistently operating across the UPMC health system to ensure compliance with the reporting requirements under the Substance Abuse and Mental Health Services Projects of Regional and National Significance (Assistance Listing No. 93.243). Effect or potential effect: The timing deficiency noted in the FFATA reporting process resulted in noncompliance with federal regulations. Questioned costs: None. Context: Total subrecipient expenditures subject to FFATA reporting were $263,959 and total federal expenditures for Substance Abuse and Mental Health Services Projects of Regional and National Significance (Assistance Listing No. 93.243) were $1,342,955 for the year ended December 31, 2025. Total federal expenditures for the year ended December 31, 2025, were $45,791,146. Identification as a repeat finding, if applicable: No. Recommendation: UPMC should ensure all control policies related to the reporting compliance processes are operating consistently across the UPMC health system and that evidence of each control is maintained. We recommend UPMC maintain a tracking log of subawards and FFATA reports to ensure they are submitted within the required timeframe. Views of responsible officials: Management concurs with this finding.
Internal Controls over Reporting Identification of the federal program: Federal Agency: U.S. Department of Health and Human Services Federal Cluster: None Assistance Listing Nos.: - 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) - 93.153, Coordinated Services and Access to Research for Women, Infants, Children, and Youth (Ryan White, Part D) Federal Award Numbers: - Ryan White, Part C: H76HA31655, H76HA25775, and H76HA00617 - Ryan White, Part D: H12HA26266 Federal Award Periods: - Ryan White, Part C: April 1, 2022 through March 31, 2025; May 1, 2022 through April 30, 2026; and May 1, 2022 through April 30, 2026 - Ryan White, Part D: August 1, 2024 through July 31, 2026 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) states the following regarding internal control: “The non-Federal entity must: Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Condition: Ryan White, Part C and Part D require the use of program income under the additive method, which requires program income earned from a federally funded program is added to the federal award amount and used to further program objectives. Under the method, allowable expenditures of program income are included on the SEFA. UPMC’s SEFA did not include expenditures related to program income, which were allowable. Cause: UPMC’s SEFA included grant funds expended under the Ryan White, Part C and Part D programs but did not include program income funds expended under the Ryan White, Part C and Part D programs for the year ended December 31, 2025. Effect or potential effect: The expenditures in the SEFA for the Ryan White, Part C and Part D programs for the year ended December 31, 2025, were understated which resulted in the improper identification of major federal programs. Questioned costs: None Context: Expenditures for the Ryan White, Part C and Ryan White, Part D were understated by $7,634,679 and $1,695,912, respectively (as compared to corrected expenditures for Ryan White, Part C and Ryan White, Part D of $8,771,633and $2,181,731, respectively), which resulted in Ryan White, Part C and Ryan White, Part D being identified as major federal programs upon inclusion of the allowable expenditures from program income. Identification as a repeat finding, if applicable: Yes, this is a repeat of 2024-004 of the prior year. Recommendation: UPMC should evaluate its internal controls over the SEFA process to ensure that reported federal expenditures include both grant expenditures and applicable program income expenditures, when required, to support the accurate reporting of federal expenditures. Views of responsible officials: Management concurs with this finding. Management has remediated the control deficiency as of December 31, 2025, and has appropriately revised its processes and internal controls to expenditures of program income in the SEFA for impacted programs.