DANA-FARBER CANCER INSTITUTE, INC. AND SUBSIDIARIES Schedule of Findings and Questioned Costs Year ended September 30, 2022 Finding Number: 2022-001 Program Information: Provider Relief Fund Federal Agency: Department of Health and Human Services/National Institutes of Health Program Name: Provider ...
DANA-FARBER CANCER INSTITUTE, INC. AND SUBSIDIARIES Schedule of Findings and Questioned Costs Year ended September 30, 2022 Finding Number: 2022-001 Program Information: Provider Relief Fund Federal Agency: Department of Health and Human Services/National Institutes of Health Program Name: Provider Relief Fund Federal Award Year: October 1, 2021 through September 30, 2022 Federal Award Numbers: See accompanying Schedule of Expenditures of Federal Awards CFDA Numbers: See accompanying Schedule of Expenditures of Federal Awards Compliance requirements: Internal Controls for Provider Relief Fund (PRF) Reporting Criteria or Requirement PRF recipients that received one or more payments exceeding $10,000 in the aggregate during a Payment Received Period are required to report on several required data elements as part of the post-payment reporting process. Reporting must be completed and submitted to HRSA by the reporting dates specified by HRSA. Additionally, Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, section 03(a) states the non-Federal entity must 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). Condition Found, Including Perspective The dollar amount of expenses reported by management in the HRSA portal Period 2 submission ($5,947,568) was incorrect. Management entered the total dollar amounts of expenses for Periods 1 and 2 rather than just the Period 2 expenses that should have been reported in the Period 2 submission. The condition found results from a misinterpretation of the PRF Reporting Period 2 submission. In completing the PRF Reporting Period 2, the HRSA website automatically populated certain PRF Reporting Period 1 data into the HRSA Reporting Period 2 portal. Management interpreted this to mean that unreimbursed COVID expenses are to be reported on a cumulative basis in the PRF Reporting Period 2 and therefore overstated unreimbursed expenses for Period 1. Institute Response Dana-Farber Cancer Institute concurs with the findings and recommendations associated with the Internal Controls for PRF Reporting and will ensure each of the data elements reported to HRSA are accurate and result in amounts consistent with its underlying records. There was an error in PRF Reporting Period 2 due to a misinterpretation of the instructions, which resulted in the double counting of Period 1 expenses. When it was determined there was an error, Dana-Farber immediately contacted HRSA to request re-opening of the Period 2 report to revise the reported expenses. HRSA did not allow for the re-opening of the reporting period and maintained that the adjustment should be submitted during the Institute?s next reporting period. Corrective Plan: Dana-Farber Cancer Institute will make the adjustment in its next reporting period, Period 5, due by September 2023. The adjustment will net down Period 1 expenses and remedy the double counting issue. As the correct interpretation of the instructions is now known to Dana-Farber, the expenses will be reported to HRSA accurately and consistent with Dana-Farber records moving forward. Contact Person: Valeria Leite Director, Research Finance Dana-Farber Cancer Institute 450 Brookline Avenue Boston, MA 02215 Ph: 617-632-3753 Email: vleite@dfci.harvard.edu Melissa Chammas Senior Director of Financial Operations Dana-Farber Cancer Institute 450 Brookline Avenue, Boston, MA., 02215 Ph: 617-582-8311 Email: Melissa_Chammas@dfci.harvard.edu