Corrective Action Plans

2025-002 Corrective Action: We will correct the application of indirect costs and reduce the very next future request for reimbursement by the overcharged indirect costs. We have also changed the circumstances that caused the limitation to be overlooked related to this specific contract.

Findings and Questioned Costs Relating to Federal Awards: Insufficient Controls Related to the Application of Indirect Cost Rates The Department will strengthen its administrative and management control processes to ensure accurate preparation and calculation for the Indirect Cost. The following corrective actions will be implemented: 1. Establish Internal Review Process: The Department will implement an excel report that includes all Grants to ensure adequate calculation and review. 2. Assign Reporting Responsibility: A designated staff member will be responsible for monitoring federal reporting requirements according to NICRA limitations. 3. Review and Approval Process: Management will implement an internal review and approval process prior to report submission to ensure accuracy and completeness.

The Blood Bank added review and approval processes to ensure only allowable charged are included in the MTDC subject to the indirect cost rate.

2022-003 Research and Development Cluster ? Assistance Listing No. 93.310 Recommendation: We recommend the Blood Bank implement procedures to ensure only allowable charges outlined within 200 CFR 200.68 are included in the Modified Total Direct Costs (MTDC) subject to the indirect cost rate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Blood Bank added review and approval processes to ensure only allowable charges are included in the MTDC subject to the indirect cost rate. Names of the contact persons responsible for corrective action: Bryan Eleazar, CFO; Lisa Alexander, Direct of Grant Accounting; Jeanette Lysse, Controller Planned completion date for corrective action plan: October 29, 2021

Timesheets are reviewed by project managers before they are submitted to payroll processing. Additionally, a reconciliation of actual to budgeted hours will be performed on a monthly basis. Documentation of the timesheet reviews will be maintained electronically. Staff time for federal grants will be supported by a completed timesheet signed by a project manager. The National Alliance Against Disparities in Patient Health does acknowledge that an additional level of review is justified as our grant volume continues to expand. The verification of work performed on a monthly basis will ensure accuracy. Project managers will meet weekly with the executive team to address any transitional issues. Evidence of this allocation review will be maintained electronically for future inspection and/or presentation to grantors or others with a need to know.

Contact person(s) responsible: Executive Director Vanessa Timmons; Associate Director Keri Moran Kuhn; Accounting Manager Linda Koonce. Corrective action planned: OCADSV added an Administrative Cost Center to its General Ledger effective 10-01-22, the beginning of FY23, and began costing administrative payroll costs to that cost center. Additionally, the organization re-trained administrative staff on direct cost-allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. OCADSV is developing a formal cost allocation plan to recover direct and indirect costs using the 10% de minimis of Modified Total Direct Cost. The allocation will be applied monthly and incorporated into the annual budgeting process. Anticipated completion date: Effective 6-21-23 and ongoing