2023-006 – Completeness and accuracy of certain programs on the Prior Year Schedules of Expenditures of Federal Awards (SEFA) - (Significant Deficiency)
Cluster: Not applicable
Sponsoring Agency: Department of Health and Human Services (DHHS) - Health Resources and Services Administration (HRSA), D...
2023-006 – Completeness and accuracy of certain programs on the Prior Year Schedules of Expenditures of Federal Awards (SEFA) - (Significant Deficiency)
Cluster: Not applicable
Sponsoring Agency: Department of Health and Human Services (DHHS) - Health Resources and Services Administration (HRSA), Department of Education (ED) and Federal Emergency Management Agency (FEMA)
Award Names: COVID-19 Provider Relief Fund and ARP (ARP) Rural Distribution (PRF), COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Portion, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) and Maternal and Child Health Federal Consolidated Programs
Award Numbers: Various
Assistance Listing Titles: COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution, COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters), COVID-19 Higher Education Emergency Relief Fund (HEERF) Student Aid Portion, COVID-19 HEERF Institutional Aid Portion, COVID-19 HEERF Minority Serving Institutions, and Maternal and Child Health Federal Consolidated Programs
Assistance Listing Number: 93.498, 97.036, 84.425E, 84.425F, 84.425L, 93.110
Award Year: 2020-2021, 2021-2022, 2019-2020, 2021-2023
Pass-through entity: Not applicable
Management has implemented additional reconciliation and review procedures over the last two years to improve the accuracy and completeness of the SEFA.
· UCOP implemented an annual SEFA review process to include the systemwide Controller and campus Controllers. UCOP also distributed one interim SEFA draft to the External Fund Managers (EFMs) that had historically been tasked with only a year-end review.
· UCOP continued to reconcile atypical federal programs (e.g., PRF, FEMA, etc.) and included in the fiscal year 2023 SEFA drafts for campus Controller review.
Beginning in FY 2024, UCOP will implement more comprehensive financial reporting controls as follows:
· Interim SEFA reports, inclusive of atypical programs, will be prepared centrally and distributed to campuses for review and alignment with campus records. Campus management will be tasked with the responsibility for overall review and signoff for both interim and final SEFA reports.
· The Systemwide Controller will also be included in the review process by performing an overall review and signoff for both interim and final SEFA reports.
With respect to the specific findings in FY2023 for atypical / nonrecurring federal programs, the following actions have been and/or will be taken:
• FEMA: A reconciliation process was implemented within UCOP in FY2023, the result of which was the discovery of the understatement referenced in the finding. FEMA expenses are now reconciled to, and obligation dates retrieved from, the Federal FEMA Grants Portal to ensure project expenses are accurately reported in the proper fiscal year. Data from the State portal is distributed to campuses for validation. UCOP has also reminded campus and medical center Controllers of the reporting requirements and will cover this topic again in future trainings. Additionally, UCOP will remind campuses and medical centers of the requirement to account for the FEMA project in the federal fund range at the time of obligation to trigger SEFA reporting.
• PRF – A reconciliation process was implemented by UCOP in FY2022 and the reconciliation itself was completed in FY2023, the result of which was the discovery of the understatement referenced in the finding. PRF expenses reported by campuses are now reconciled to the HRSA online portal which will continue for the duration of the program. UCOP has also reminded campus and medical center Controllers of their responsibility to report on these dollars for their entire enterprise (Faculty Practice Group, School of Medicine, etc.). As with all other federal funding, PRF amounts will continue to be part of the SEFA reports distributed to campuses for review and signoff. Coordination between campuses and medical centers will be expected for this review and signoff.
• HEERF – while the program ended in FY2023, UCOP will apply lessons learned to any future “special” funding. When atypical programs such as this are awarded in the future, UCOP will provide more consistent guidance upfront and establish more consistent accounting and reporting requirements for campuses and the medical centers to follow. Requirements will include regular reporting of these dollars to UCOP with a reconciliation of campus ledgers to any sponsor reporting. As with all other federal funding, amounts will be part of the SEFA reports distributed to campuses for review and signoff.
• Program Income – UCOP will develop and conduct expanded training to campus Controllers, EFMs and their staff to include SEFA requirements generally, including treatment for program income (and other SEFA exclusions), new review procedures, etc. UCOP will target training for the spring of 2024.
For inquiries regarding this finding, please contact Barbara Cevallos at barbara.cevallos@ucop.edu who is responsible for the corrective action.