Corrective Action Plan
Finding 2023-003
Internal Control Deficiency
Activities Allowed or Unallowed/Allowable Costs
Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA); Assistance Listing ...
Corrective Action Plan
Finding 2023-003
Internal Control Deficiency
Activities Allowed or Unallowed/Allowable Costs
Identification of the federal program: Federal Grantor: United States Department of Health and Human Services, Health Resources and Services Administration (HRSA); Assistance Listing No. 93.498, Provider Relief Fund and American Rescue Plan (ARP) Rural Distributions
Condition: Per discussion with management, OU Medicine, Inc. has processes and internal
controls in place to comply with the terms and conditions of the award and the reporting
requirements. However, management did not retain documentation evidencing the performance
of these controls.
Corrective Action:
At the beginning of the pandemic, OU Health created working groups to evaluate the requirements for COVID-19 funding received and ensure the funds were only used for allowable purposes. The working groups were assisted by outside consultants to stay updated on the reporting requirements as the continued to evolve.
As part of the Uniform Guidance audit, OU Health provided documentation of the Provider Relief Fund review process that explained how eligible costs were identified and submitted. To ensure internal controls are documented to the level necessary under current audit standards, OU Health will develop a checklist to document the review and approval of supporting documentation of contract labor costs as reported federal expenditures. The supporting documentation will be reviewed by management to ensure expenses charged to the federal program are allowable and have not been reimbursed under another federal program. The checklist will be retained with the existing report.
Responsible Official: Bernard Githinji, AVP Corporate Controller
Anticipated Completion Date: April 30, 2024