Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Federal Program: Research & Development ALN Number: Various Federal Award Years: Various Criteria Internal Controls Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements of Federal Awards, (2 CFR 200) section 200.303(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 statues, 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 The Health System utilizes Workday, a cloud based system, to provide human resources and payroll applications. The Health System’s management of Workday includes maintaining the application system layer of the information technology (IT) control environment. The Health System relies on the Workday vendor to support infrastructure layers through Service Organization Control (SOC) Type-1 reporting. Processes that support compliance and administration of the R&D program rely on Workday IT application controls. The Health System also utilizes Infor, a cloud based system, as the entity’s general ledger. The Health System's management of Infor includes maintaining the application system layer of the IT control environment and relies on the Infor vendor to support infrastructure layers through SOC 1 reporting. Processes that support compliance and administration of the R&D program rely on Infor IT application control. During our testing, we observed there were no inappropriate changes to the Workday and Infor application controls directly related to specific controls over compliance related to the R&D program, however we noted the following deficiencies in operating effectiveness of the Health System’s general IT controls environment: Workday 1) The Health System performed and documented a Workday change review during the fiscal year; however, the supporting document did not include sufficient appropriate evidence demonstrating such review. Specifically, management maintained an Excel spreadsheet that noted the changes to the business process definitions were appropriate; however, there were no screenshots to document the completeness and accuracy of the report from the system, or evidence of the sign off by the reviewer. Additionally, we noted appropriate evidence of testing and/or approval was not maintained for 4 of 25 sampled changes during the period. 2) The Health System performed a Workday User Access Review (UAR) during the fiscal year and maintained certain evidence demonstrating the UAR occurred, including required access updates; however, the Health System did not maintain specific evidence that all users were reviewed, approved and updated where necessary (i.e. evidence of the completeness & accuracy for pre and post user listing was not available). 3) With respect to our access removal testing, we noted that the Health System implemented automated controls to remove terminated user access in both Workday and Infor, following processing in Workday. We also tested a sample of 25 terminated users to determine whether their access was removed timely and noted that 9 of the sampled users were not removed timely prior processing in Workday. Cause The conditions above relate to the following, respectively: 1) The condition occurred because the Health System did not formally define the procedures to establish requirements for the change review, including retaining evidence of the completeness and accuracy of the review. Additionally, management does not have a centralized process for maintaining evidence of testing and approval for changes. 2) The condition occurred because the Health System did not formally define the procedures to document a complete and accurate UAR. 3) The exception occurred due to delays in supervisors’ timely reporting of terminations. Possible Asserted Effect Failure to have a reliable general IT control environment over logical access and change management may result in unauthorized changes being made to Workday, which may result in erroneous reliance on the operating effectiveness of automated IT controls, over allowability. Failure to have effective internal controls over allowability may result in federal awards being utilized for unallowable expenditures not in accordance with the federal statues, regulations, and terms and conditions of federal awards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend that management review and emphasize the change management policies and procedures with key personnel to help ensure that the Workday change review is performed to address change management risks for the system. In addition, we recommend that evidence related to the review, as well as the testing and approval of changes is maintained. Additionally, we recommend that management maintain documentation of the completeness and accuracy of the user access review to ensure that all users are reviewed, approved, and corrective actions taken. Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
2024-001 (Repeat Finding) Retaining Sliding Scale Determination Documentation Special Tests and Provisions ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) US Department of Health and Human Services Contract Numbers H80CS30749-06 and H80CS30749-07 Contract Periods April 1, 2022 – March 31, 2023 and April 1, 2023 – March 31, 2024 Conditions and Criteria: The requirement under 45 CFR 75.361 provides requirements for the retention of records for grantees. In addition, 2 CFR 200.303 provides requirements to establish and maintain effective internal controls over Federal awards. Specifically, it states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Health and Human Services awarding agency of pass-through entity in the case of a subrecipient. In the 2023 audit, for 5 out of 40 samples selected for testing, it was noted that OCHS did not retain the proper documents that the patients had submitted that included their income and family size or the documents completed by OCHS showing the sliding fee discount determination for these patients. Effect: The effect is that records that are required to be retained were not retained and evidence of how the sliding fee discount was determined could not be examined. Questioned Costs: Any likely questioned costs could not be determined since compliance testing was unable to be performed due to the lack of documentation. It should be noted that there were no exceptions for 35 samples that were able to be tested, and for 5 samples with insufficient documentation, 3 had partial documentation of income (i.e., pay stubs) and 2 had no documentation of income as it was not maintained. However, the sliding scale calculation was completed for all 40 samples. Cause: Determining the sliding fee discount level for each patient is reassessed on an annual basis. During the year, there was employee turnover in the compliance department. Although OCHS has a records retention policy, there was a lack of monitoring in place to ensure that the requirement under 45 CFR 75.361 was adhered to. Auditor Recommendation: A procedure should be put in place to monitor whether the record retention policy is followed. Current Status: During the current year, fiscal 2024 audit testing, 5 of 40 samples lacked support for the sliding fee scale determination. However, for all 5 samples it was noted the sliding fee was determined during fiscal 2023. There is a three-year documentation retention requirement per 45 CFR 200.303. If asked to produce documentation for fiscal year 2023, OCHS would not be able to do so, therefore, the 2023 fiscal year finding was repeated. Planned Corrective Action: See the following Corrective Action Plan section for management’s planned corrective action.
2024-001 (Repeat Finding) Retaining Sliding Scale Determination Documentation Special Tests and Provisions ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) US Department of Health and Human Services Contract Numbers H80CS30749-06 and H80CS30749-07 Contract Periods April 1, 2022 – March 31, 2023 and April 1, 2023 – March 31, 2024 Conditions and Criteria: The requirement under 45 CFR 75.361 provides requirements for the retention of records for grantees. In addition, 2 CFR 200.303 provides requirements to establish and maintain effective internal controls over Federal awards. Specifically, it states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Health and Human Services awarding agency of pass-through entity in the case of a subrecipient. In the 2023 audit, for 5 out of 40 samples selected for testing, it was noted that OCHS did not retain the proper documents that the patients had submitted that included their income and family size or the documents completed by OCHS showing the sliding fee discount determination for these patients. Effect: The effect is that records that are required to be retained were not retained and evidence of how the sliding fee discount was determined could not be examined. Questioned Costs: Any likely questioned costs could not be determined since compliance testing was unable to be performed due to the lack of documentation. It should be noted that there were no exceptions for 35 samples that were able to be tested, and for 5 samples with insufficient documentation, 3 had partial documentation of income (i.e., pay stubs) and 2 had no documentation of income as it was not maintained. However, the sliding scale calculation was completed for all 40 samples. Cause: Determining the sliding fee discount level for each patient is reassessed on an annual basis. During the year, there was employee turnover in the compliance department. Although OCHS has a records retention policy, there was a lack of monitoring in place to ensure that the requirement under 45 CFR 75.361 was adhered to. Auditor Recommendation: A procedure should be put in place to monitor whether the record retention policy is followed. Current Status: During the current year, fiscal 2024 audit testing, 5 of 40 samples lacked support for the sliding fee scale determination. However, for all 5 samples it was noted the sliding fee was determined during fiscal 2023. There is a three-year documentation retention requirement per 45 CFR 200.303. If asked to produce documentation for fiscal year 2023, OCHS would not be able to do so, therefore, the 2023 fiscal year finding was repeated. Planned Corrective Action: See the following Corrective Action Plan section for management’s planned corrective action.
2024-001 (Repeat Finding) Retaining Sliding Scale Determination Documentation Special Tests and Provisions ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) US Department of Health and Human Services Contract Numbers H80CS30749-06 and H80CS30749-07 Contract Periods April 1, 2022 – March 31, 2023 and April 1, 2023 – March 31, 2024 Conditions and Criteria: The requirement under 45 CFR 75.361 provides requirements for the retention of records for grantees. In addition, 2 CFR 200.303 provides requirements to establish and maintain effective internal controls over Federal awards. Specifically, it states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Health and Human Services awarding agency of pass-through entity in the case of a subrecipient. In the 2023 audit, for 5 out of 40 samples selected for testing, it was noted that OCHS did not retain the proper documents that the patients had submitted that included their income and family size or the documents completed by OCHS showing the sliding fee discount determination for these patients. Effect: The effect is that records that are required to be retained were not retained and evidence of how the sliding fee discount was determined could not be examined. Questioned Costs: Any likely questioned costs could not be determined since compliance testing was unable to be performed due to the lack of documentation. It should be noted that there were no exceptions for 35 samples that were able to be tested, and for 5 samples with insufficient documentation, 3 had partial documentation of income (i.e., pay stubs) and 2 had no documentation of income as it was not maintained. However, the sliding scale calculation was completed for all 40 samples. Cause: Determining the sliding fee discount level for each patient is reassessed on an annual basis. During the year, there was employee turnover in the compliance department. Although OCHS has a records retention policy, there was a lack of monitoring in place to ensure that the requirement under 45 CFR 75.361 was adhered to. Auditor Recommendation: A procedure should be put in place to monitor whether the record retention policy is followed. Current Status: During the current year, fiscal 2024 audit testing, 5 of 40 samples lacked support for the sliding fee scale determination. However, for all 5 samples it was noted the sliding fee was determined during fiscal 2023. There is a three-year documentation retention requirement per 45 CFR 200.303. If asked to produce documentation for fiscal year 2023, OCHS would not be able to do so, therefore, the 2023 fiscal year finding was repeated. Planned Corrective Action: See the following Corrective Action Plan section for management’s planned corrective action.
2024-001 (Repeat Finding) Retaining Sliding Scale Determination Documentation Special Tests and Provisions ALN 93.224 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) US Department of Health and Human Services Contract Numbers H80CS30749-06 and H80CS30749-07 Contract Periods April 1, 2022 – March 31, 2023 and April 1, 2023 – March 31, 2024 Conditions and Criteria: The requirement under 45 CFR 75.361 provides requirements for the retention of records for grantees. In addition, 2 CFR 200.303 provides requirements to establish and maintain effective internal controls over Federal awards. Specifically, it states that financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Health and Human Services awarding agency of pass-through entity in the case of a subrecipient. In the 2023 audit, for 5 out of 40 samples selected for testing, it was noted that OCHS did not retain the proper documents that the patients had submitted that included their income and family size or the documents completed by OCHS showing the sliding fee discount determination for these patients. Effect: The effect is that records that are required to be retained were not retained and evidence of how the sliding fee discount was determined could not be examined. Questioned Costs: Any likely questioned costs could not be determined since compliance testing was unable to be performed due to the lack of documentation. It should be noted that there were no exceptions for 35 samples that were able to be tested, and for 5 samples with insufficient documentation, 3 had partial documentation of income (i.e., pay stubs) and 2 had no documentation of income as it was not maintained. However, the sliding scale calculation was completed for all 40 samples. Cause: Determining the sliding fee discount level for each patient is reassessed on an annual basis. During the year, there was employee turnover in the compliance department. Although OCHS has a records retention policy, there was a lack of monitoring in place to ensure that the requirement under 45 CFR 75.361 was adhered to. Auditor Recommendation: A procedure should be put in place to monitor whether the record retention policy is followed. Current Status: During the current year, fiscal 2024 audit testing, 5 of 40 samples lacked support for the sliding fee scale determination. However, for all 5 samples it was noted the sliding fee was determined during fiscal 2023. There is a three-year documentation retention requirement per 45 CFR 200.303. If asked to produce documentation for fiscal year 2023, OCHS would not be able to do so, therefore, the 2023 fiscal year finding was repeated. Planned Corrective Action: See the following Corrective Action Plan section for management’s planned corrective action.